Fuja v. Stephens
2025 UT App 109
Utah Ct. App.2025Background
- Tannin and Megan Fuja sued Corbett Stephens for alleged wrongful acts committed while he was employed by the City of Woodland Hills related to construction on a neighboring property.
- The Fujas initially named the city and multiple city officials but later focused their claims solely on Stephens.
- The core allegation was that Stephens, acting in his official city capacity, willfully and fraudulently mismanaged city code enforcement and provided false testimony regarding the disputed site.
- The district court initially dismissed most claims but left the claims against Stephens pending due to a then-current interpretation of Utah's Governmental Immunity Act (UGIA).
- Subsequent appellate decisions, particularly Graves II, clarified the law regarding governmental immunity for employees, affecting this case.
- On appeal, the Fujas also raised various constitutional challenges to the UGIA, claiming it violated several rights under the Utah Constitution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Governmental Immunity | Stephens’ immunity was waived for fraud/willful misconduct | No waiver; actions as city official protected by UGIA | Immunity not waived; claim barred |
| Application of UGIA | UGIA § 202(3)(c)(i) is a blanket waiver for willful misconduct | Provision only exempts exclusive remedy rule, not immunity | No blanket waiver; only narrow exception |
| Constitutional Claims | UGIA violates rights to property, petition, courts, due process | UGIA is constitutional; claims inadequately briefed | Challenges inadequately briefed; rejected |
| Merits of Enforcement | Sufficient facts alleged to survive motion to dismiss | Failure to state claim; protected official actions | Dismissal affirmed on immunity grounds |
Key Cases Cited
- Graves v. Utah County Government, 551 P.3d 1029 (Utah Ct. App. 2024) (clarifies that UGIA does not provide a blanket waiver of immunity for government employees’ willful misconduct; instead, only exempts exclusive remedy provision)
- Scott v. Universal Sales, Inc., 356 P.3d 1172 (Utah 2015) (broad interpretation of 'governmental function' under immunity statutes)
- Blanch v. Farrell, 436 P.3d 285 (Utah Ct. App. 2018) (standard for reviewing motions to dismiss)
- Hudgens v. Prosper, Inc., 243 P.3d 1275 (Utah 2010) (motion to dismiss standard)