Christensen v. Juab Sch Dist, 424 P.3d 108

Hadley Christensen, a Juab School District fifth‑grade teacher, was criminally charged with aggravated sexual abuse of a child based on allegations including that he occupied a "position of special trust" as the victim's former teacher; charge arose from an unsanctioned sleepover during break.
The information alleged three aggravating elements; the court granted directed verdicts dismissing two aggravators (including "position of special trust" and injury), the jury acquitted on the remaining theory.
Christensen sued Juab School District under Utah Code § 52‑6‑201 (the Reimbursement Statute) seeking recovery of reasonable attorney fees and costs for his successful criminal defense.
The district court granted Christensen partial summary judgment, concluding the allegations in the information were sufficient to trigger reimbursement under the statute’s "under color of authority" prong.
Juab appealed, arguing the statute requires an inquiry into the actual facts and employment‑relatedness of the conduct (time, place, nature), not merely the allegations.
The Utah Supreme Court affirmed, holding reimbursement is assessed based on the allegations in the criminal information (for the color‑of‑authority prong) and that Christensen met the statute’s requirements; the court declined to address allocation of which costs are recoverable because parties had stipulated the amount.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reimbursement under Utah Code § 52‑6‑201 attaches based on allegations in the criminal information or requires fact‑specific inquiry into actual events	Christensen: Right attaches where the information alleges employment‑relatedness (here, "position of special trust")	Juab: Statute requires inquiry into actual employment‑relatedness (time, place, nature) of the charged conduct; mere allegations insufficient	Court: Attach based on allegations in the information for the "under color of authority" prong; rejects reexamination of actual guilt or events (follows Acor)
Whether Christensen satisfied the "under color of authority" prong given the sleepover was not school‑sanctioned	Christensen: Allegation that he was the victim's former teacher pleaded a "position of special trust," satisfying the prong	Juab: Because the event was outside his employment and unsanctioned, he was not acting under color of authority	Court: The information alleged he occupied a position of special trust (teacher‑student relationship), which alleges acts under color of authority as defined by Watkins; statutory elements met

Acor v. Salt Lake City Sch. Dist., 247 P.3d 404 (Utah 2011) (Reimbursement Statute evaluated at a general level; employer‑relatedness determined by allegations in the information and not by reexamining guilt)
State v. Watkins, 309 P.3d 209 (Utah 2013) (definition of "position of special trust": must show a position of authority that enabled the perpetrator to exercise undue influence over the victim)
Redevelopment Agency of Salt Lake City v. Tanner, 740 P.2d 1296 (Utah 1987) (stipulations generally binding; party may not challenge stipulated issues absent basis to invalidate stipulation)