Griffin v. Snow Christensen and Martineau, 467 P.3d 833

Griffin sued Snow Christensen & Martineau (SCM) for legal malpractice and filed an amended complaint on the court-ordered deadline (Aug 28, 2017); process server left papers at SCM’s office.
SCM moved to quash service and to dismiss; the district court granted the motion orally, signed the minutes, and directed SCM’s counsel to submit a proposed order.
SCM submitted a proposed “Order of Dismissal with Prejudice,” which the court signed and docketed on April 10, 2018.
Griffin filed a post-judgment motion (Rule 52(b)/59 variants) on May 9, 2018; SCM contended the motion was untimely because the April 10 order was an entry of judgment that started the 28-day clock.
The district court concluded the April 10 Order was not a separate judgment under Utah R. Civ. P. 58A(a), treated Griffin’s post-judgment motion as timely, vacated the April 10 Order, and granted relief on the merits; SCM appealed interlocutorily.
The Utah Supreme Court affirmed: the April 10 Order did not satisfy Rule 58A(a)’s separate-judgment requirement, so the entry-of-judgment clock never began from that document; waiver argument failed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 10 Order constituted a separate judgment under Utah R. Civ. P. 58A(a) (thus starting the time to file post-judgment motions)	Griffin: April 10 Order was an order confirming the motion decision, not a 58A(a) separate judgment, so the 28-day post-judgment clock had not begun	SCM: April 10 Order adjudicated all claims and was a separate judgment, so Griffin’s May 9 motion was untimely	Court: April 10 Order was not a 58A(a) separate judgment (title, content, and function mattered); it did not trigger entry of judgment—Griffin’s motion was timely
Whether Griffin waived the separate-document challenge by treating the order as a proposed judgment	Griffin: no waiver; timeliness questions require mechanical application of Rule 58A	SCM: waiver because Griffin acknowledged the order as a proposed judgment in district-court pleadings	Court: no waiver; mechanical application required for timeliness questions and Bankers Trust waiver exception did not apply
Role of federal precedent (e.g., In re Cendant) in interpreting Rule 58A	Griffin: Utah rule controls, but federal cases are persuasive for guidance	SCM: argued district court incorrectly applied additional requirements from federal cases	Court: federal decisions interpreting Fed. R. Civ. P. 58 are persuasive and In re Cendant’s description of a proper separate judgment (self-contained, notes relief, omits reasons) is helpful—not an extra statutory requirement

Central Utah Water Conservancy Dist. v. King, 297 P.3d 619 (Utah 2013) (describes earlier confusion about when decisions become final and prompted rule revisions)
In re Cendant Corp., 454 F.3d 235 (3d Cir. 2006) (describes characteristics of a proper separate judgment distinct from opinion)
Bankers Trust Co. v. Mallis, 435 U.S. 381 (U.S. 1978) (discusses separate-document requirement and when waiver may apply)
United States v. Indrelunas, 411 U.S. 216 (U.S. 1973) (addresses mechanical application of separate-document rule in timeliness contexts)
Giusti v. Sterling Wentworth Corp., 201 P.3d 966 (Utah 2009) (earlier discussion of problems with relying on non-separate decisions to start appeal periods)