Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Horne
2012 UT 66
| Utah | 2012Background
- Certified question from the Tenth Circuit asks Utah law on preclusion for a Lindberg-style laches dismissal with a written opinion.
- FLDSA challenged trust reformation in 2005 Utah probate proceedings; FLDSA did not participate at first.
- Federal suit in Oct 2008 raised constitutional challenges to trust reformation; stay pending settlement.
- Utah Supreme Court Lindberg (2010) dismissed FLDSA’s writ petition on laches grounds, ruling mostly on the merits of laches.
- Federal district court later held Lindberg was not a merits judgment for res judicata; this court clarifies Utah law on preclusion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is a Lindberg-style laches dismissal a merits judgment for res judicata? | FLDSA argues dismissal was not on the merits. | Lindberg dismissed on laches merits, thus preclusive. | Yes; Lindberg is on the merits and precludes later claims. |
| Must a laches analysis weigh the merits of underlying claims? | Lindberg did not examine underlying constitutional merits. | Laches analysis focuses on delay and prejudice, not merits. | Merits need not be weighed; harm-based factors are not required in laches analysis. |
| Can structural Establishment Clause claims escape laches time-bar? | Establishment claims are structural and not subject to waiver/time bar. | Time bars apply to all constitutional claims, including structural ones. | Structural claims can become time-barred like other claims. |
| Does rule 41 and related Utah federal/state practice align with preclusion in a certified case? | Writ-denial grounds should not automatically preclude later actions. | Dismissals on the merits have preclusive effect under rule 41 and Utah law. | Dismissals on the merits under rule 41 are preclusive in Utah courts. |
Key Cases Cited
- Mack v. Utah State Dep't of Commerce, Div. of Secs., 2009 UT 47 (Utah 2009) (three-part res judicata test governing claim preclusion)
- Lindberg, Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Lindberg, 2010 UT 51 (Utah 2010) (laeches analysis; laches can yield res judicata effect)
- Madsen v. Borthick, 769 P.2d 245 (Utah 1988) (dismissal on the merits defined under Rule 41)
- Semtek Int'l., Inc. v. Lockheed Martin Corp., 531 U.S. 497 (U.S. 2001) (federal rule 41 practice; preclusion frontier across jurisdictions)
- Costello v. United States, 365 U.S. 265 (U.S. 1961) (dismissals on the merits generally preclude later actions)
- Shoup v. Bell & Howell Co., 872 F.2d 1178 (4th Cir. 1989) (preclusion when dismissal rests on merits)