Teamsters Local 222 v. Utah Transit Auth., 424 P.3d 892

Utah Transit Authority (UTA) changed rail supervisors from salaried to hourly; a group of supervisors sought to unionize and enlisted Teamsters Local 222 as their bargaining agent.
Teamsters collected 23 authorization cards (a majority) and asked UTA to recognize it; UTA refused, disputing whether the supervisors counted as "employees" entitled to collective bargaining under the Utah Public Transit District Act (UPTDA).
Teamsters and the supervisors sued for a declaratory judgment that the supervisors were an appropriate bargaining unit and sought an order compelling UTA to bargain; they moved for summary judgment on whether supervisors are "employees" under the UPTDA.
The district court granted summary judgment for Teamsters/supervisors, concluding supervisors are "employees," and ordered a card check; Teamsters failed to maintain majority support and later lost a secret ballot election, leading the district court to enter final judgment that Teamsters was not the bargaining representative.
UTA moved for a new trial and appealed. While appeal was pending, the supervisors formally and democratically voted not to unionize, which ended the dispute before the court finally resolved the statutory issue on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the supervisors are "employees" under the UPTDA (i.e., entitled to collective bargaining)	Supervisors/Teamsters: UPTDA covers supervisors as employees; summary judgment correct.	UTA: Supervisors not covered; district court erred.	Not decided on the merits — appeal dismissed as moot because supervisors voted not to unionize before final judgment.
Whether the case remains justiciable after supervisors' vote not to unionize	Teamsters: The controversy over these supervisors' rights remained alive (implicit)	UTA: The supervisors' vote mooted the dispute; no live relief available.	Court: Moot — controversy eliminated; no meaningful relief possible.
Whether the case could be decided to prevent future unionization attempts (ripeness)	UTA: Court should decide now to avoid future disputes	Teamsters: Future attempts are hypothetical and not ripe	Court: Declining to resolve hypothetical future disputes as unripe.
Whether the voluntary cessation/mootness exception applies (i.e., supervisors stopped unionizing to evade review)	UTA: Supervisors voluntarily ceased conduct to avoid appellate review; exception should apply	Supervisors: Their formal, democratic decision was sincere and not strategic cessation	Court: Exception inapplicable — plaintiffs (supervisors) were not defendants evading review; no evidence of strategic manipulation.

Utah Transit Auth. v. Local 382 of Amalgamated Transit Union, 289 P.3d 582 (Utah 2012) (mootness doctrine and dismissal duty when controversy eliminated)
State v. Steed, 357 P.3d 547 (Utah 2015) (mootness requires requested relief could affect parties' rights)
Baird v. State, 547 P.2d 713 (Utah 1976) (dismissal required when action becomes moot)
Redwood Gym v. Salt Lake Cty. Comm’n, 624 P.2d 1138 (Utah 1981) (ripeness requires an actual or imminent clash of legal rights)
Barnard v. Utah State Bar, 857 P.2d 917 (Utah 1993) (declaratory judgment requires a justiciable controversy and ripeness)
Rio Grande Silvery Minnow v. Bureau of Reclamation, 601 F.3d 1096 (10th Cir. 2010) (vacatur and dismissal when case becomes moot prior to final adjudication)
United States v. W. T. Grant Co., 345 U.S. 629 (1953) (voluntary cessation exception: defendant free to resume challenged conduct argues against mootness)
County of L.A. v. Davis, 440 U.S. 625 (1979) (voluntary cessation does not necessarily moot a case if the defendant may resume conduct)
City News & Novelty, Inc. v. City of Waukesha, 531 U.S. 278 (2001) (courts should guard against evasion of review through temporary cessation of conduct)