Glaittli v. State of Utah
332 P.3d 953
| Utah | 2014Background
- Glaittli sued the State of Utah for injuries when his boat heaved and struck him after a storm-induced wave action at Jordanelle Reservoir; State immunity and a waiver exception were at issue.
- The Jordanelle marina, docks, slips, and reservoir are State-owned and operated by the Utah Division of Parks & Recreation; the floating dock was tethered to shore by eight cables and could be lengthened/shortened by a hand-operated winch.
- Water levels rose rapidly in June 2008, necessitating frequent cable adjustments; a June 10 storm produced large waves; Glaittli observed wave action and attempted to adjust the lines on the dock.
- Glaittli alleged the State failed to adjust dock level, warn of unsafe conditions, properly secure the docks, and construct a breakwater.
- The district court held the injury fell within the natural condition exception to immunity; the court of appeals affirmed; the Utah Supreme Court reverses, holding Jordanelle Reservoir is not a natural condition on land, remanding for negligence analysis under the general waiver.
- The opinion proceeds to frame the issue as a statutory interpretation of natural condition, with remand for determining proximate cause if negligence is found.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a reservoir is a natural condition on land under the statute | Glaittli argues water/waves are natural, thus the reservoir (a natural condition) triggers immunity. | State contends reservoir is a topographical, land-based condition, but not a natural condition due to human-made dam creation. | Reservoir is not a natural condition on the land. |
| If reservoir is natural, whether Glaittli's injury arose from that natural condition | Injury arose from natural conditions (wind/waves) interacting with land features. | Injury arose from the interaction of natural conditions with artificial reservoir design. | moot, as reservoir is not a natural condition. |
Key Cases Cited
- Grappendorf v. Pleasant Grove City, 173 P.3d 166 (2007 UT 84) (defines natural condition and avoids swallowing immunity)
- Blackner v. State, 48 P.3d 949 (2002 UT 44) (avalanche as natural condition extending immunity)
- Francis v. State, 321 P.3d 1089 (2013 UT 65) (limits natural condition to topographical, persistent land features)
- Weber ex rel. Weber v. Springville City, 725 P.2d 1360 (Utah 1986) (distinguishes natural watercourse from reservoir context)