Allen v. Moyer
2011 UT 44
Utah2011Background
- In 2008, Allen and Moyer were involved in a motor-vehicle accident in Utah.
- Allen filed a small-claims action for property damage and the court awarded him $4,831.50 after a bench trial.
- About six months later, Allen filed a personal-injury action in the Third District Court; Moyer moved for summary judgment on claim preclusion grounds.
- The district court applied Dennis v. Vasquez (on point) and held the personal-injury claim barred by claim preclusion.
- Allen argued claim preclusion does not apply to small-claims judgments and challenged Faux v. Mickelsen; the court rejected these arguments and held claim preclusion applies to small-claims judgments.
- The court concluded applying claim preclusion to small-claims judgments promotes finality, judicial economy, and consistent judgments, and it instructed notice to litigants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does claim preclusion apply to small-claims judgments? | Allen contends it does not apply to small claims. | Moyer argues preclusion applies to small-claims judgments to promote finality and economy. | Yes, claim preclusion applies to small-claims judgments. |
| Does Faux v. Mickelsen bar applying claim preclusion to small-claims judgments? | Allen asserts Faux prevents application to all small-claims judgments. | Moyer argues Faux is limited to counterclaims and does not foreclose claim preclusion in small claims generally. | Faux does not control; it does not categorically exempt small-claims judgments from claim preclusion. |
| Should the rule be applied prospectively due to fairness concerns? | Allen urges prospective application to avoid unfairness based on Faux. | Moyer notes reliance interests and that Dennis controlled when suits were filed. | Court did not limit retroactive application, applying the rule to the present case. |
Key Cases Cited
- Dennis v. Vasquez, 72 P.3d 135 (2003 UT App 168) (applied claim preclusion to small-claims judgment (controversy in the case))
- Faux v. Mickelsen, 725 P.2d 1372 (Utah 1986) (limited counterclaims in small-claims context; not a general bar on claim preclusion)
- Turner v. Hi-Country Homeowners Ass'n, 910 P.2d 1223 (Utah 1996) (issue preclusion not available due to lack of record; distinguishes from claim preclusion)