Biedermann v. Wasatch County
2015 UT App 274
Utah Ct. App.2015Background
- Appellants own parcels in Brighton Estates subdivision in Wasatch County.
- County Council adopted a resolution in May 2013 proposing a Brighton Estates Special Service District with boundaries listed by parcel/lot.
- County later approved formation and adopted the boundaries as proposed in the list.
- Appellants filed a district-court complaint for declaratory relief challenging proper establishment of the District.
- County moved to dismiss for lack of standing under Utah Code § 17D-1-212(1); the district court dismissed.
- Court must accept factual allegations in the complaint as true for Rule 12(b)(1) dismissals and consider in a light most favorable to appellants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appellants have standing to challenge the District’s creation | Appellants claim their property is within the District boundaries and thus they are within the class authorized to sue. | Only properties specifically identified on the resolution’s boundary list may have standing to challenge the District. | Burton has standing for her listed parcels; Biedermann and Chesley lack standing. |
| Whether the District’s boundaries include appellants’ property | Appellants’ lots are island-like within the District and should be considered within its boundaries. | Boundaries are defined by the resolution’s list; enclaves do not prove inclusion. | The boundaries are limited to the list; enclaves are not within the District. |
| Whether appellants’ alleged injuries meet the individualized-injury standard | Appellants allege non-benefit from the District’s services as the injury. | Standing requires individualized injury; the record and briefing are insufficient to analyze this. | Argument inadequately briefed; not addressed on the merits. |
| Whether the district court erred in considering the Map/records attached to the complaint | Maps show inclusion of certain parcels; the complaint relies on them to prove boundaries. | Court should rely on the statutory boundary list, not extrinsic maps. | Court’s reliance on statutory boundary list upheld; maps insufficient to alter boundaries. |
Key Cases Cited
- St. Benedict’s Dev. Co. v. St. Benedict’s Hosp., 811 P.2d 194 (Utah 1991) (standing and judicial review framework for complaints)
- Brown v. Division of Water Rights of Dep’t of Nat. Res., 228 P.3d 747 (Utah 2010) (standing as jurisdictional, evaluated like dispositive motion)
- Osguthorpe v. Wolf Mountain Resorts, LC, 232 P.3d 999 (Utah 2010) (standing analysis under Utah law)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1982) (standing requires causation, redressability, and injury)
- Marion Energy, Inc. v. KFJ Ranch P’ship, 267 P.3d 863 (Utah 2011) (statutory interpretation governs boundaries and non-contiguity)
- Koerber v. Mismash, 315 P.3d 1053 (Utah App. 2013) (acceptance of complaint allegations; no fact outside pleadings)