Salt Lake City v. Inland Port Authority, 524 P.3d 573

Background

The Utah Legislature created the Utah Inland Port Authority (UIPA) and designated ~16,000 acres (including ~13,000 acres in NW Salt Lake City and land in West Valley City and Magna) as "authority jurisdictional land."
The Utah Inland Port Authority Act requires municipalities containing authority land to "allow an inland port" as a permitted/conditional use and bars those municipalities from prohibiting transport/unloading/loading/temporary storage of natural resources on authority land.
The Act also originally redirected portions of property and sales/use taxes collected on authority land to UIPA to fund the port.
Salt Lake City sued, alleging the zoning and tax provisions violate the Utah Constitution's Uniform Operation of Laws Clause and the Ripper Clause (prohibiting delegation/interference with municipal functions and money). The district court granted UIPA summary judgment.
The Utah Supreme Court affirmed as to the zoning provisions (rational-basis review; not an unlawful delegation) but declined to decide the tax challenges because 2022 legislative amendments may have mooted them; the Court retained jurisdiction and ordered supplemental briefing on mootness and whether the tax funds constitute "municipal money."

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether zoning provisions violate Uniform Operation of Laws Clause by singling out three municipalities	The Act impermissibly treats Salt Lake City, West Valley, and Magna differently, imposing burdensome statewide project costs on them alone	The classification is rationally related to a legitimate statewide economic development purpose (maximize long-term economic benefit)	Affirmed for defendant: classification survives rational-basis review (legislative objective is legitimate and related to disparity)
Whether tax provisions violate Uniform Operation of Laws Clause	Redirecting property/sales taxes from the three municipalities is disparate treatment that lacks a reasonable legislative objective	Redirecting taxes funds a statewide public purpose (port) and classification was defensible under earlier scheme	Not decided on merits: Court stayed decision because 2022 amendments may moot the claim; parties ordered to brief mootness
Whether zoning provisions violate the Ripper Clause by delegating municipal functions	The Act impermissibly delegates municipal zoning/land-use decisions to UIPA or outside actors	The statute issues direct legislative mandates to municipalities (not delegations to UIPA); it does not entrust powers to a special commission	Affirmed for defendant: zoning provisions are legislative mandates, not forbidden delegations under the Ripper Clause
Whether tax provisions violate the Ripper Clause by interfering with "municipal money"	Redirecting tax revenue amounts to unconstitutional interference/delegation with municipal money and functions	The pre-amendment scheme was authorized by statute; 2022 amendments give Salt Lake City new negotiating power and designation as "primary municipality," which may change the analysis	Not decided on merits: Court reserved judgment and ordered supplemental briefing on mootness and whether the funds qualify as "municipal money"

Key Cases Cited

Merrill v. Utah Labor Commission, 223 P.3d 1089 (Utah 2009) (rational-basis review of statutory classifications informs Uniform Operation analysis)
Count My Vote, Inc. v. Cox, 452 P.3d 1109 (Utah 2019) (three-step Uniform Operation of Laws Clause test: classification, disparate treatment, and reasonable legislative objective)
Taylorsville City v. Mitchell, 466 P.3d 148 (Utah 2020) (applying rational-basis review where no suspect class or fundamental right implicated)
State v. Canton, 308 P.3d 517 (Utah 2013) (historical and modern approaches to the Uniform Operation Clause)
Utah Transit Auth. v. Local 382 of Amalgamated Transit Union, 289 P.3d 582 (Utah 2012) (statutory amendment can moot an appeal when relief would have no meaningful practical effect)
Maxfield v. Herbert, 284 P.3d 647 (Utah 2012) (strong presumption of constitutionality for statutes)
In re J.P., 648 P.2d 1364 (Utah 1982) (amendment to statute may moot an appeal if it prevents requested relief from affecting litigants' rights)