In the Matter of The United Effort Plan Trust, 2013 UT 5

UEP Trust reformed in 2006 as secular charitable trust under district court supervision.
Special fiduciary appointed to manage Trust amid ongoing administration and litigation.
Trust sale of Berry Knoll Farm sought; FLDS members and bishops sought intervention under Rule 24(a).
District court denied intervention for lack of legally cognizable interest; public hearing allowed input from non-parties.
Appeals concluded the district court properly denied intervention under Rule 24(a)(1) and (2) due to lack of right and insufficient interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 24(a)(1) mandatorily allows intervention based on §75-7-405(3).	Appellants contend §75-7-405(3) creates an unconditional right to intervene.	District court held §75-7-405(3) does not confer an unconditional intervenor right.	No unconditional right to intervene under Rule 24(a)(1); statute not binding as automatic right.
Whether Appellants have a sufficient interest under Rule 24(a)(2) to intervene.	Appellants claim a special ecclesiastical interest in Berry Knoll and Trust administration.	Interest is not legally cognizable; no direct stake in disputed Trust property.	Appellants’ interests not sufficient; no right to intervene under Rule 24(a)(2).

Taylor-West Weber Water Improvement Dist. v. Olds, 224 P.3d 709 (Utah Supreme Court, 2009) (established framework for Rule 24(a) review (mixed questions))
In re Adoption of Baby B., 2012 UT 35 (Utah Supreme Court, 2012) (analyze standard of review for Rule 24(a) mixed questions)
Parduhn v. Bennett, 112 P.3d 495 (Utah Supreme Court, 2005) (deference framework for Rule 24(a)(2) determinations)
Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Lindberg, 238 P.3d 1054 (Utah Supreme Court, 2010) (reformation of Trust and loss of standing challenges)
Interstate Land Corp. v. Patterson, 797 P.2d 1101 (Utah Court of Appeals, 1990) (standing/intervention considerations for trust disputes)