Pruett v. Anderson, 296 P.3d 797

Defendants Jerad Anderson, Kathy Anderson, Carelyn Marble, and Amanda Marble appeal a district court denial of a rule 4(e) motion to extend time for filing an appeal.
The prior appeal was dismissed for lack of jurisdiction in Pruett v. Anderson; dismissal was without prejudice to a post-final-order appeal after rule 4(e) motion resolution.
District court entry granted judgment on June 28, 2012: damages on counterclaim and judgment for Pruett on unlawful detainer; other claims not present.
Pruett timely moved for a new trial, later withdrawn; rule 4(b) tolling applied until a July 26, 2012 order disposing of the withdrawal, extending the deadline.
Under Rule 4(e), a party may obtain an extension for good cause or excusable neglect, filed within 30 days after expiration.
The district court denied the motion, reasoning Defendants had not shown good cause or excusable neglect; Defendants argue misguidance by the courts affected timing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion denying the rule 4(e) extension	Andersons claim misguidance by the courts caused delay	Court misled them about pursuing deposit claim and timing	No abuse; district court properly denied extension
Whether the appeal is jurisdictionally barred notwithstanding the extension denial	They sought relief from the underlying judgment	Timing and extension denial foreclose appeal rights	Appeal dismissed for lack of jurisdiction

Reisbeck v. HCA Health Servs. of Utah, Inc., 2000 UT 48 (Utah Supreme Court 2000) (trial court has broad discretion on rule 4(e) extensions; requires good cause or excusable neglect)