347 P.3d 21
Utah Ct. App.2015Background
- Plaintiffs are current and former UDOC transportation-unit correctional officers who received a three-step pay-grade incentive under a 1996 agreement that was modified in 2000.
- The 2000 modified agreement provided that officers who served at least three years in the transportation unit “will not lose any steps” and that their pay “maintains minimally their current rate of pay.”
- UDOC later discontinued the incentive for new hires, and in 2008 implemented a systemwide straight-line career ladder pay scale that applied to all employees.
- Plaintiffs sued, alleging UDOC breached the modified agreement by moving transportation officers into the new pay scheme and thereby failing to preserve a perpetual three-step pay differential between transportation and non-transportation officers.
- UDOC moved for summary judgment, arguing the modified agreement unambiguously did not promise a permanent, unchangeable three-step differential but only that officers would not lose steps already earned and would be treated the same as other officers for raises and promotions.
- The district court granted summary judgment for UDOC; the Court of Appeals affirmed, holding Plaintiffs’ reading was not reasonably supported by the contract language.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the modified agreement is ambiguous as to whether transportation officers are entitled to a perpetual three-step pay-grade differential | The contract’s language on benchmarking, preservation of steps, and promotion raises is ambiguous and can be read to require maintaining a constant three-step differential in perpetuity | The agreement unambiguously promises only that officers who reach three years won’t lose steps and will be treated like other officers for raises/promotions; it does not guarantee a forever-exempt differential | Court held the agreement is not reasonably susceptible to Plaintiffs’ perpetual-differential interpretation; summary judgment for UDOC affirmed |
Key Cases Cited
- WebBank v. American Gen. Annuity Serv. Corp., 54 P.3d 1139 (Utah 2002) (summary judgment inappropriate if contract ambiguity creates factual dispute about parties’ intent)
- Bahr v. Imus, 250 P.3d 56 (Utah 2011) (appellate review of summary judgment is for correctness)
- Daines v. Vincent, 190 P.3d 1269 (Utah 2008) (defines when contract language is ambiguous and role of extrinsic evidence)
- Watkins v. Henry Day Ford, 304 P.3d 841 (Utah 2013) (extrinsic evidence may support ambiguity only if reasonably supported by the contract language)