Supernova Media, Inc. v. Shannon's Rainbow, LLC
2013 UT 7
| Utah | 2013Background
- Supernova Media, Inc. and Joycelyn Engle appeal the denial of their motions to intervene as of right in two Utah district court cases involving Shannon’s Rainbow LLCs and related interests.
- The cases concern competing interests in distribution control of the Shannon’s Rainbow film and its collateral assets, including liens and potential foreclosure.
- Pia Anderson Dorius Reynard & Moss, LLC (PADRM) represented the Shannon’s Rainbow entities and later sought to foreclose liens; SummitWorks and its principals faced related claims and a settlement was later reached.
- Supernova attempted to intervene both derivatively and on behalf of the Shannon’s Rainbow LLCs to obtain injunctive relief and to stay proceedings pending related New York actions.
- The district courts denied intervention and sealed related records; later, settlement discussions proceeded and motions to dismiss were granted.
- The Utah Supreme Court reverses, holding Supernova was entitled to intervene and the sealing order was improper, and remands for consolidation and to set aside the settlement allowing Supernova full participation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Intervention as of right | Supernova asserted a right to intervene under Rule 24(a). | PADRM argued Supernova lacked timeliness and an adequate interest; contested representation. | Supernova entitled to intervene as of right. |
| Sealing order proper | Supernova argued sealing violated Rule 4-202.04(3) and the public’s access rights. | Defendants claimed privilege and no need for detailed findings; sealing was appropriate. | sealing order improper; required findings and public-interest consideration. |
Key Cases Cited
- Millard Cnty. v. Utah State Tax Comm’n ex rel. Intermountain Power Agency, 823 P.2d 459 (Utah 1991) (settlement cannot moot a pending motion to intervene)
- Jenner v. Real Estate Servs., 659 P.2d 1072 (Utah 1983) (timeliness of intervention analyzed for interference with court process)
- Ball v. Public Service Comm. (In re Questar Gas Co.), 175 P.3d 545 (Utah 2007) (permissive/intervention considerations; timing and settlement impact)
- Chatterton v. Walker, 938 P.2d 255 (Utah 1997) (practical impairment standard for intervention)
- Lima v. Chambers, 657 P.2d 279 (Utah 1982) (intervention analyzed under early doctrine; later amended rule 24(a))
- State Farm Mut. Auto. Ins. Co. v. Allgier, 2011 UT 47 (Utah) (public access rights and balancing interests in sealing records)
- Bosh v. 2011 UT 60, 266 P.3d 788 (Utah 2011) (intervention and interests in preserved or assigned claims)