Utah Alunite Corporation v. Jones, 366 P.3d 901

Background

In 2006 Central Iron County Water Conservancy District (Water District) applied to appropriate groundwater in Wah Wah Valley; the State Engineer published notice and ~300 protests were filed—SITLA did not protest.
In 2012 SITLA and its lessee Utah Alunite Corporation (UAC) filed a competing water-appropriation application; the Water District protested that application.
In May 2014 the State Engineer issued decisions granting water rights to both the Water District and to SITLA/UAC, but SITLA/UAC’s grant was subject to the Water District’s senior priority.
SITLA and UAC sought judicial review in district court, characterizing the State Engineer’s decision as an effective denial; the district court dismissed their petition for lack of subject-matter jurisdiction.
The district court held SITLA and UAC lacked standing because they were not parties to the Water District’s original (informal) adjudication and had not exhausted administrative remedies (SITLA failed to timely protest; UAC failed to seek intervention or request formal adjudication).
The Utah Court of Appeals affirmed, concluding that although SITLA and UAC were "aggrieved persons," they were not "aggrieved parties" under the Administrative Procedure Act (UAPA) and so lacked standing to obtain judicial review of the State Engineer’s decision.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an "aggrieved person" under Utah Code § 73-3-14 automatically has standing to seek judicial review of a State Engineer order	SITLA/UAC: The statutory phrase "person aggrieved" alone suffices for standing to seek judicial review	State Engineer/Water Dist.: § 73-3-14 incorporates UAPA, so an aggrieved person must also be a "party" under UAPA to obtain review	Court: § 73-3-14 requires compliance with UAPA; standing requires both aggrievement and party status (aggrieved party)
Whether being a party in a separate, parallel administrative proceeding confers party status in the Water District's informal adjudication	SITLA/UAC: Their involvement in a related proceeding and known interest in the valley sufficed	State Engineer/Water Dist.: Party status is procedural—must be a respondent, protestant, or intervenor in that specific proceeding; parallel participation does not qualify	Court: Parallel-party status does not confer party status in the Water District’s proceeding; SITLA/UAC were not parties there
Whether the informal nature of the original adjudication prevented SITLA/UAC from intervening and therefore deprived them of review	SITLA/UAC: Informal adjudication and State Engineer’s knowledge of their interest should not bar review	State Engineer/Water Dist.: Informal adjudication rules limit intervention; appellants could have requested formal adjudication or timely protested/intervened	Court: Appellants could have sought conversion to a formal proceeding or protested; failure to use those remedies means lack of party status and no standing
Whether equitable considerations (notice to State Engineer of interest, harsh result) justify excusing procedural prerequisites	SITLA/UAC: The State Engineer knew their interest and decision was plainly adverse; equity favors allowing review	State Engineer/Water Dist.: Allowing review despite UAPA requirements would create unbounded precedent and undermine statutory procedural limits	Court: Equity does not override statutory requirement that an aggrieved person must be a party under UAPA; cannot depart from statutory scheme

Key Cases Cited

Washington County Water Conservancy Dist. v. Morgan, 82 P.3d 1125 (Utah 2003) (standing requires an "aggrieved person" with actual/potential injury)
Marion Energy, Inc. v. KFJ Ranch P'ship, 267 P.3d 863 (Utah 2011) (statutory interpretation reviewed for correctness)
Packer v. Utah Attorney General’s Office, 307 P.3d 704 (Utah Ct. App. 2013) (lack of standing deprives court of jurisdiction over appeal)
Badger v. Brooklyn Canal Co., 922 P.2d 745 (Utah 1996) (parties without a legally cognizable grievance lack standing)