Segota v. Young Chrysler, 470 P.3d 479

Segota bought a truck from Young, alleging Young promised features that were not present and refused to add/repair them; she sued Young and Nationwide (bond insurer) for breach of contract and fraud.
After Nationwide answered, the court set discovery deadlines; Nationwide served timely initial disclosures (one day late), but Segota did not serve initial disclosures during the fact discovery period.
During fact discovery Segota conducted no written discovery, noticed no depositions, filed no substantive motions, and only later dismissed some defendants; her first meaningful activity came after Nationwide moved for summary judgment.
Segota belatedly served initial disclosures and opposed the motions only after the fact discovery deadline had passed; Young later served identical disclosures; Segota sought extensions that the court denied.
The district court found Segota’s late disclosures unjustified and harmful, imposed the Utah R. Civ. P. 26(d)(4) sanction barring undisclosed witnesses/documents, and—because Segota had no admissible evidence—granted summary judgment dismissing her claims with prejudice.
On appeal the Utah Court of Appeals affirmed, holding the court did not abuse its discretion in denying extensions, imposing the Rule 26 sanction, or granting summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused discretion by denying Segota’s motions to extend discovery and response deadlines	Segota argued the case had just begun, no discovery had been done, and counsel had personal/work hardships warranting extensions	Defendants argued Segota failed to prosecute, delayed until after motions were filed, and offered insufficient excuse for extensions	Court did not abuse discretion; denying extensions was within docket-management discretion
Whether the court abused discretion in imposing a Rule 26(d)(4) sanction and granting summary judgment	Segota argued her late disclosures were harmless (defendants later served identical disclosures) and any harm could be remedied by extending discovery	Defendants argued late disclosures deprived them of meaningful discovery and justify the automatic Rule 26 sanction barring undisclosed evidence, making Segota unable to prove her case	Court did not abuse discretion: late disclosures violated Rule 26, were not harmless, sanction barred evidence, and summary judgment was proper because plaintiff had no admissible evidence

Keystone Ins. Agency, LLC v. Inside Ins., LLC, 445 P.3d 434 (Utah 2019) (plaintiff disclosures are central; Rule 26 sanctions and disclosure design explained)
Brown v. Glover, 16 P.3d 540 (Utah 2000) (broad discretion for continuances; reversal only for clear abuse)
Ruiz v. Killebrew, 459 P.3d 1005 (Utah 2020) (summary judgment reviewed for correctness)
Solis v. Burningham Enters., Inc., 342 P.3d 812 (Utah Ct. App. 2015) (district courts have broad discretion in discovery scheduling)
Ghidotti v. Waldron, 442 P.3d 1237 (Utah Ct. App. 2019) (sanctions review for abuse of discretion)
Sleepy Holdings LLC v. Mountain West Title, 370 P.3d 963 (Utah Ct. App. 2016) (sanctions rulings upheld when within court’s discretion)
Poulsen v. Frear, 946 P.2d 738 (Utah Ct. App. 1997) (judge’s ordinary admonition does not show judicial bias)