2014 UT 30
Utah2014Background
- Glaittli sued the State of Utah for injuries from his boat being struck while docked at Jordanelle Reservoir marina.
- The marina, docks, slips, and reservoir are owned by the State and operated by state agencies.
- The floating dock’s position depended on water levels and wind, requiring frequent cable adjustments.
- A June 2008 storm caused large waves; Glaittli walked onto the dock to adjust lines and was injured when his boat’s bow struck him.
- The district court granted immunity-based dismissal, concluding the injury arose from a natural condition; the court of appeals affirmed.
- The Utah Supreme Court reversed, holding Jordanelle Reservoir is not a natural condition on land; remand for negligence determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jordanelle Reservoir is a natural condition on the land. | Glaittli argues water in the reservoir is a natural condition. | State argues reservoir (dam-created) is a natural condition on land. | Reservoir is not a natural condition on the land. |
| If a reservoir were a natural condition, whether Glaittli's injuries arose from that natural condition. | Injuries caused by interaction with natural condition. | Injury would arise from natural condition; immunity may apply. | Not reached; issue deemed irrelevant because reservoir not a natural condition. |
Key Cases Cited
- Blackner v. State, 2002 UT 44 (Utah 2002) (natural condition immunity extended to an avalanche)
- Grappendorf v. Pleasant Grove City, 2007 UT 84 (Utah 2007) (limits natural condition immunity for artificial interactions on land)
- Francis v. State, 2013 UT 65 (Utah 2013) (limits natural condition immunity for transient/land-unrelated natural threats)
- Weber ex rel. Weber v. Springville City, 725 P.2d 1360 (Utah 1986) (distinguishes natural watercourse from artificial changes in water law context)