McCaffrey v. Anderson, 2026 UT 14

Derek Anderson sought to incorporate West Hills, a new town between Hideout and Kamas, under Utah’s municipal incorporation code. 1
The incorporation process allowed specified landowners to request exclusion from proposed boundaries during an initial notice period and again after the first public hearing, but not after the second public hearing. 2
Anderson’s final modified map added appellee landowners after the statutory exclusion deadline had passed, and the Lieutenant Governor certified the petition for the 2025 general election. 3
The landowners sued to enjoin the election, claiming the code violated the Utah Constitution’s Uniform Operation of Laws Clause by treating similarly situated landowners differently. 4
The district court granted summary judgment to the landowners, applying rational basis review but finding the exclusion scheme unreasonable and insufficiently connected to legislative purposes. 5
The Utah Supreme Court reversed and reinstated certification, holding the exclusion scheme constitutional under the modern uniform-operation framework and declining to reach the original-meaning argument. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the exclusion scheme violate uniform operation? 7	Landowners said later-added owners lost exclusion rights arbitrarily.	Anderson said the cutoff rationally ends endless boundary changes.	No; the time-based cutoff survives rational basis review. 8
Should the court affirm on original-meaning grounds? 9	Landowners said the code also fails the Clause’s original meaning.	Anderson urged reversal under the modern test only.	No; the court declined to decide that unsettled issue first. 10

DIRECTV v. Utah State Tax Comm'n, 364 P.3d 1036 (Utah 2015) (rational basis requires any rational or reasonable basis for the classification 11)
Bingham v. Gourley, 556 P.3d 53 (Utah 2024) (upholding a time-based line as reasonable 12)
State v. Outzen, 408 P.3d 334 (Utah 2017) (modern uniform-operation test has three steps 13)
Taylorsville City v. Mitchell, 466 P.3d 148 (Utah 2020) (rational-basis review is a low bar and classifications are usually upheld 14)
Tischmak v. Utah State Tax Comm'n, 574 P.3d 63 (Utah 2025) (any legitimate objective and reasonable relationship suffice under rational basis 15)
State v. Angilau, 245 P.3d 745 (Utah 2011) (upholding a seemingly arbitrary time or age line under rational basis 16)
Orvis v. Johnson, 177 P.3d 600 (Utah 2008) (summary-judgment review is for correctness 17)