Glaittli v. State, 294 P.3d 626

Glaittli sued the State of Utah for negligence in connection with injuries at Jordanelle Reservoir marina.
The State owns and operates Jordanelle Reservoir, including docks and boat slips; dock cables are adjusted by a hand winch due to water level.
Glaittli’s boat was tethered to a floating dock; large waves during a storm prompted him to adjust lines on the dock.
The State allegedly failed to adjust dock levels, warn of unsafe conditions, and properly secure docks; a breakwater was not built.
Trial court dismissed under the Governmental Immunity Act’s natural condition exception, and Glaittli appealed to challenge immunity.
The court reviews a motion to dismiss as a question of law and interprets the Act’s waivers and exceptions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the natural condition exception bars the waiver of immunity.	Glaittli argues immunity does not apply under the natural condition exception.	State contends the natural condition exception preserves immunity.	Yes; natural condition exception applies, blocking the waiver.
Whether wind‑induced waves on Jordanelle Reservoir constitute a natural condition on public lands.	Wind and waves are natural conditions on land.	Waves on water touching land can be natural conditions if linked to land surface.	Yes; water waves on the reservoir are a natural condition on land, so immunity applies.

Blackner v. Utah Department of Transportation, 48 P.3d 949 (Utah, 2002) (natural condition exception applies even if government acts negligently in response to natural condition)
Grappendorf v. Pleasant Grove City, 173 P.3d 166 (Utah, 2007) (wind gust not a natural condition on land; natural condition must be on land)
Stuckman ex rel. Nelson v. Salt Lake City, 919 P.2d 568 (Utah, 1996) (river is a natural condition because it flows on land)
Hall v. Utah State Dep’t of Corr., 24 P.3d 95 (Utah, 2001) (statutory interpretation and standard for reviewing immunity determinations)