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Fitzgerald v. Spearhead InvestmentsFitzgerald v. Spearhead Investments

Utah Supreme Court
Jul 22, 2021
Case No. 20190644
Versions:493 P.3d 644
2021 UT 34

2021 UT 34

IN THE

SUPREME COURT OF THE STATE OF UTAH

KEN M. FITZGERALD and FIVE C.J. PROPERTIES, LLC,

Appellants,

v.

SPEARHEAD INVESTMENTS, LLC and ALPINE EAST INVESTORS, LLC,

Appellees.1

No. 20190644

Heard February 10, 2021

Filed July 22, 2021

On Interlocutory Appeal

Fourth District, Utah County

The Honorable Thomas Low

No. 170401272

Attorneys:

Bryan H. Booth, Salt Lake City, for appellants

Thomas W. Seiler, Jared L. Anderson, Provo, for appellee

JUSTICE HIMONAS authored the opinion of the Court, in which

CHIEF JUSTICE DURRANT, ASSOCIATE CHIEF JUSTICE LEE, JUSTICE

PEARCE, and JUSTICE PETERSEN joined.

JUSTICE HIMONAS, opinion of the Court:

INTRODUCTION

¶1 The Dutch have a saying that “promises make debt, and

debt makes promises.” Today, we expand on this commercial

proverb to address what the law requires when a promise to pay

is not kept and the limitations period has run. Specifically, we

consider whether the equitable estoppel doctrine offers a discrete

basis for tolling a statute of limitations in Utah. We hold that it

does.

FITZGERALD V. SPEARHEAD INVESTMENTS, LLC

Opinion of the Court

¶2 This case comes to us as an interlocutory appeal from the

denial of Ken Fitzgerald and Five C.J. Properties, LLC‘s

(collectively, Owners) motion for summary judgment on their

claim for declaratory judgment/quiet title with respect to the

subject property (the Property). Here are the essential facts:

Owners executed a trust deed note with Alpine East Investors,

LLC for the Property, promising to pay the note in full within two

years. They didn‘t. After the foreclosure limitations period had

expired, and despite numerous promises made—and

subsequently broken—to pay the debt owed, Owners sought two

results from the district court: (1) to enjoin Alpine East from

foreclosing its trust deed on the Property, and (2) a determination

that Alpine East had no valid interest in the Property. Alpine East

responded by invoking the doctrine of equitable estoppel, which

would toll the limitations period and estop Owners from using

the statute of limitations to quiet title. Owners, however, argued

before the district court, and now on appeal to us, that equitable

estoppel is not a stand-alone basis for defeating a statute of

limitations defense because this court has incorporated it into the

equitable discovery doctrine. If Owners are right, then Alpine East

is unable to toll the foreclosure limitations period because it

cannot satisfy the elements of equitable discovery.

¶3 Our response to Owners’ view of equitable estoppel is a

hard no. To reach our conclusion, we juxtapose equitable estoppel

with equitable discovery and find that, though similar in name

and function, they‘re separate equitable doctrines that are invoked

in distinct circumstances. As such, we hold that equitable estoppel

may be invoked as a stand-alone basis for tolling a statute of

limitations. But we clarify that a mere promise to make good on a

debt, without more, is insufficient to toll a limitations period

under the equitable estoppel doctrine, even if a party has relied

upon that promise. Still, we do not address equitable estoppel‘s

specific application to this case—we leave that to the district court

as it is better situated to make the determination in the first

instance. Accordingly, we vacate the district court‘s interlocutory

order denying summary judgment and remand for further

proceedings consistent with this opinion.

BACKGROUND

¶4 In 2008, Owners executed and made payable to Alpine

East a trust deed note for the Property. The parties also executed

and recorded a trust deed to secure the note against the Property.

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Opinion for of the Court

The note was due two years later. When the due date had passed,

Owners had yet to make a payment toward the note.2

¶5 Pursuant to Utah Code section 70A-3-118(1), Alpine East

had a limitations period of six years to file an action to foreclose

the trust deed or record a notice of default on the property. Seven

days before that limitations period expired, Brian Hansen, the

manager of Alpine East, spoke by telephone with Fitzgerald

regarding payment of the note. During the nearly hour-long

conversation, Hansen specifically mentioned to Fitzgerald the

possibility of foreclosing on the Property. Fitzgerald did not

dispute the amount or validity of the debt, pleaded with Hansen

not to foreclose, and gave assurances of forthcoming payment or,

alternatively, conversion of the note into equity in the company

that would develop the Property. Fitzgerald pitched that Alpine

East could earn more under this alternative proposal than what it

was owed under the note. None of Fitzgerald‘s assurances were

committed to writing. Hansen now alleges that he did not initiate

a foreclosure of the Property before the limitations period had run

because of these assurances.

¶6 Eight days after the presumed statute of limitations had

expired, Hansen again spoke over the phone with Fitzgerald for

nearly an hour. During this call, Fitzgerald recommitted to either

make payment under the note or convert the debt into equity in

one of his development companies. Fitzgerald also agreed to

“work something out” to extend the note. When Hansen asked

Fitzgerald to send an email confirming their plan to extend the

note, Fitzgerald indicated that he would not sign anything until

the State of Utah finished its then-current criminal investigation of

his father and family.

¶7 Over a year later and well after the presumed limitations

period had expired, Owners sought a court determination that the

note and trust deed were unenforceable and that Alpine East had

no interest in the property. Shortly thereafter, Owners filed a

motion for summary judgment against Alpine East, arguing that

the statute of limitations had expired and that Alpine East was

therefore barred from foreclosing the trust deed. The district court

FITZGERALD V. SPEARHEAD INVESTMENTS, LLC

Opinion of the Court

granted the motion, declaring that the limitations period for

enforcing the trust deed had expired before Alpine East recorded

a notice of default or filed an action to foreclose. The district court

also entered a judgment against Alpine East, enjoining them from

foreclosing on the trust deed or otherwise enforcing the note.

With both orders, the court concluded that Alpine East had no

right, title, or interest in the Property.

¶8 Months later, however, in a separate case with related

facts and parties, the Utah Court of Appeals held that dilatory

tactics to stave off foreclosure until a limitations period had

expired could toll the limitations period under the doctrine of

equitable estoppel. Jeppesen v. Bank of Utah, 2018 UT App 234, ¶ 33,

438 P.3d 81. In so holding, the court of appeals delineated

between equitable estoppel and equitable discovery. Id. ¶¶ 30, 32.

Equitable estoppel, the court explained, tolls a limitations period

when the plaintiff had knowledge of the cause of action but was

induced by the other party to delay the action until after the

period had run; equitable discovery tolls a statute of limitations

when a plaintiff does not discover the cause of action because of

the defendant‘s concealment. Id.

¶9 Based upon the holding in Jeppesen and following the

district court‘s subsequent amended judgment granting attorney‘s

fees to appellants, Alpine East filed a Rule 59 motion to revise the

district court‘s prior ruling. Alpine East argued Owners had made

promises that raised issues of material fact that precluded

summary judgment under the doctrine of equitable estoppel.

Relying on Jeppesen, the court granted the motion because it found

a question of fact as to “whether Fitzgerald made promises to pay

or to convert the debt which induced Alpine East not to foreclose

within the statute of limitations.”

¶10 Owners petitioned for permission to take an interlocutory

appeal of the district court‘s ruling. We granted the appeal to

consider whether the doctrine of equitable estoppel has been

incorporated into the equitable discovery doctrine. We have

jurisdiction under Utah Code section 78A-3-102(3)(j).

STANDARD OF REVIEW

¶11 On interlocutory appeal, we review grants and denials of

summary judgment for correctness. Anderson Dev. Co. v. Tobias,

2005 UT 36, ¶ 19, 116 P.3d 323. “Summary judgment is only

appropriate if there are no genuine issues of material fact and the

moving party is entitled to judgment as a matter of law.” Herland

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Opinion for of the Court

v. Izatt, 2015 UT 30, ¶ 9, 345 P.3d 661 (citing UTAH R. CIV. P. 56(c)). We view the facts and indulge reasonable inferences in the light

most favorable to Alpine East, the nonmoving party. Id.

ANALYSIS

¶12 Our analysis clarifies the difference between equitable

estoppel and equitable discovery. Although similar in name and

function, these equitable doctrines each apply in distinct

circumstances.

¶13 Owners argue that Jeppesen v. Bank of Utah, 2018 UT App

234, 438 P.3d 81, which the district court relied on in granting

Alpine East‘s Rule 59 Motion, is bad law because the doctrine of

equitable estoppel, as applied to statutes of limitations, has been

incorporated into the concealment prong of the equitable

discovery doctrine. For authority, Owners point to this court‘s

statement in Russell Packard Development, Inc. v. Carson

that

equitable discovery has its “genesis in estoppel” and is

“essentially a claim of equitable estoppel.” 2005 UT 14, ¶ 26, 108

P.3d 741 (citation omitted). Thus, they assert, Alpine East must

make the initial showing required under equitable discovery: that

it did not know nor reasonably should it have known of its cause

of action in time to comply with the limitations period because of

the defendant‘s concealment. So, as Owners understand it, a party

that knew the facts supporting its claim at the time the statute of

limitations began to run—like Alpine East with its foreclosure

claim—would never have the limitations period tolled.

¶14 Alpine East, on the other hand, argues that Jeppesen was

correct to hold that equitable estoppel is an independent basis for

tolling a statute of limitations. Thus, a party need not make an

initial showing that it did not know the facts underlying the cause

of action. Accordingly, Alpine East asserts, a party who had

knowledge of the cause of action but was reasonably induced by

the debtor to delay the action until after the limitations period

may use the doctrine of equitable estoppel to toll the period.

¶15 We agree with Alpine East and the Jeppeson holding. In

explaining our conclusion, we first address the difference between

the two doctrines. We then use this occasion to clarify that a mere

promise to pay, without more, even though relied upon by a

party, is insufficient to toll a statute of limitations under the

doctrine of equitable estoppel. Ultimately, we vacate the district

court‘s interlocutory order granting Alpine East‘s Rule 59 Motion,

FITZGERALD V. SPEARHEAD INVESTMENTS, LLC

Opinion of the Court

6

and remand for further proceedings not inconsistent with this

opinion.

I.

A. Equitable Estoppel vs. Equitable Tolling

¶16 Though equitable estoppel and equitable discovery both

operate to toll statutes of limitations, they are distinct doctrines

with distinct applications. We clarify that equitable estoppel is

“invoked in cases where the plaintiff knew of the existence of his

cause of action but the defendant‘s conduct caused him to delay in

bringing [suit],” and equitable discovery is “invoked in cases

where the plaintiff is ignorant of his cause of action because of the

defendant‘s fraudulent concealment.”3 Ellul v. Congregation of

Christian Bros., 774 F.3d 791, 802 (2d Cir. 2014) (citation omitted).4

We note that while some jurisdictions, such as the Second

Circuit, have used equitable discovery and equitable tolling

interchangeably, other jurisdictions consider equitable tolling a

narrow but independent doctrine. See, e.g., Sebelius v. Auburn Reg’l

Med. Ctr., 568 U.S. 145, 164 (2013) (Sotomayor, J., concurring)

(stating that equitable tolling applies when a party is unaware of a

cause of action due to “circumstances outside both parties’

control“). Utah courts have split the difference and viewed

equitable tolling as only part of the standard equitable discovery

analysis. See Grynberg v. Questar Pipeline Co., 2003 UT 8, ¶ 65, 70

P.3d 41 (“To the extent that Utah subscribes to the principle of

equitable tolling, it has been developed almost exclusively

through application of the discovery rule to claims that were not

or could not have been discovered prior to the running of the

statute of limitations.“).

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Opinion for of the Court

7

Yet we also note that both doctrines require an “evaluation of the

reasonableness of a plaintiff‘s conduct in light of the defendant‘s

fraudulent or misleading conduct.” See Russell Packard Dev., Inc. v.

Carson, 2005 UT 14, ¶ 26, 108 P.3d 741.

¶17 The equitable estoppel doctrine comes from the “maxim

that no man may take advantage of his own wrong.” Glus v.

Brooklyn E. Dist. Terminal, 359 U.S. 231, 232 (1959). This maxim is

deeply rooted in American jurisprudence, id. at 232, and guides

our statute of limitations tolling jurisprudence in Utah. See, e.g.,

Rice v. Granite Sch. Dist., 456 P.2d 159, 163 (Utah 1969). We apply

the equitable doctrines when we recognize that a defendant has

unjustly “lull[ed] an adversary into a false sense of security

thereby subjecting his claim to the bar of limitations” and is then

In Russell Packard, this court limited the application of

equitable discovery to two circumstances. See supra ¶ 16 n.3. We

have seemed to acknowledge that the second circumstance—the

“unusual circumstances” prong—serves the purpose of equitable

tolling. See Beaver Cnty. v. Prop. Tax Div., 2006 UT 6, ¶¶ 25–26, 128

P.3d 1187. The inclusion of exceptional circumstances in the

equitable discovery analysis may have made a separate equitable

tolling analysis unnecessary. Estes v. Tibbs, 1999 UT 52, ¶ 7, 979

P.2d 823 (“Every case in which we have addressed a ‘special

circumstances exception’ has dealt with tolling a statute of

limitations through application of the discovery rule.“).

Although there is no nationwide consensus, Utah precedent is

closer to the Eighth Circuit than it is to the Second Circuit (which

includes concealment as part of equitable tolling). This view of

tolling as a sub-category of the discovery rule is consistent with

the Eighth Circuit‘s description of equitable tolling in Bell v. Fowler

because equitable discovery in Utah applies to one circumstance

where defendant misconduct is required (concealment), and one

where it is not required (exceptional circumstance). See 99 F.3d

262, 266 n.2 (8th Cir. 1996).

Notwithstanding the distinction among “equitable tolling”

and “equitable discovery” in Utah, we cite to jurisdictions in

which the terms are used interchangeably in this opinion and

make note accordingly. Further, this opinion merely clarifies that

equitable discovery is distinct from equitable estoppel. This

opinion changes nothing regarding the doctrine of equitable

discovery. See generally, e.g., Russell Packard, 2005 UT 14; Berneau v.

Martino, 2009 UT 87, 223 P.3d 1128.

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Opinion of the Court

8

“heard to plead that very delay as a defense to the action when

brought.” Id. And we see no reason to stray from this guiding

principle today even though Alpine East was aware of the facts

underlying its cause of action before the limitations period had

run.5

We further acknowledge that concealment is not the only

way a defendant may induce an adversary to postpone legal

action, and so to forsake this doctrine, even absent concealment,

would be to allow parties to take advantage of their own wrong.

Obviously, we will not go there.

¶18 We begin with equitable estoppel. The doctrine operates

to toll a statute of limitations if a plaintiff can establish three

elements:

(1) a statement, admission, act, or failure to act by

one party inconsistent with a claim later asserted;

(2) reasonable action or inaction by the other party

taken on the basis of the first party‘s statement,

admission, act, or failure to act; and (3) injury to the

second party that would result from allowing the

first party to contradict or repudiate such statement,

admission, act, or failure to act.

Jeppesen v. Bank of Utah, 2018 UT App 234, ¶ 33, 438 P.3d 81

(quoting Travelers Ins. Co. v. Kearl, 896 P.2d 644, 647 (Utah Ct. App.

1995)).

¶19 The most important inference we draw from these

elements for our purposes today is that equitable estoppel may be

invoked even when the plaintiff is aware of the facts giving rise to

a cause of action. This principle stands in stark contrast to the

equitable discovery doctrine, in which the plaintiff must show he

was not aware of the facts giving rise to a cause of action. Ellul,

774 F.3d at 802. Indeed, in Rice, this court made no requirement

that the plaintiff make an initial showing that she did not know

nor reasonably should she have known the facts underlying her

cause of action in order to equitably estop the defendant from

invoking a statute of limitations defense. Compare Rice, 456 P.2d at

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9

163, with Berneau v. Martino, 2009 UT 87, ¶ 23, 223 P.3d 1128

(stating that “the plaintiff must make an initial showing that he

did not know nor should have reasonably known the facts

underlying the cause of action in time to reasonably comply with

the limitations period” in order to invoke the equitable discovery

rule). This is because equitable estoppel merely requires that a

“party has been induced to refrain from using such means or

taking such action as lay in his power, by which he might have

retrieved his position and saved himself from loss.” Rice, 456 P.2d

at 162 (quoting Benner v. Indus. Accident Comm‘n, 159 P.2d 24, 26

(Cal. 1945)). Thus, equitable estoppel is “[u]nlike equitable tolling,

which is invoked in cases where the plaintiff is ignorant of his

cause of action because of the defendant‘s fraudulent

concealment.” Ellul, 774 F.3d at 802 (citation omitted).

¶20 We are not alone in recognizing equitable estoppel as a

discrete doctrine in the statute-of-limitations milieu. At least six

United States Circuit Courts of Appeals have recognized that

equitable estoppel is distinct from equitable discovery and doesn‘t

require a plaintiff to be unaware of the facts underlying his cause

of action. See Ellul, 774 F.3d at 802; Ramirez-Carlo v. United States,

496 F.3d 41, 48 (1st Cir. 2007) (“Equitable tolling applies when the

plaintiff is unaware of the facts underlying his cause of action,

while equitable estoppel applies when a plaintiff who knows of

his cause of action reasonably relies on the defendant‘s conduct or

statements in failing to bring suit.” (citations omitted));6 Bell v.

Fowler, 99 F.3d 262, 266 n.2 (8th Cir. 1996) (“[E]quitable tolling is

appropriate when the plaintiff, despite all due diligence, is unable

to obtain vital information bearing on the existence of his

claim. . . . Equitable estoppel presupposes that the plaintiff knows

of the facts underlying the cause of action but delayed filing suit

because of the defendant‘s conduct.” (citation omitted) (internal

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10

quotation marks omitted));7 Stitt v. Williams, 919 F.2d 516, 522 (9th

Cir. 1990) (“[T]he better reasoning states that equitable tolling

applies when the plaintiff is unaware of his cause of action, while

equitable estoppel applies when a plaintiff who knows of his

cause of action reasonably relies on the defendant‘s statements or

conduct in failing to bring suit.“);8 Cook v. Deltona Corp., 753 F.2d

1552, 1563 (11th Cir. 1985) (“‘Equitable estoppel arises where the

parties recognize the basis for suit, but the wrongdoer prevails

upon the other to forego enforcing his right until the statutory

time has lapsed. The doctrine of equitable tolling, on the other

hand, is grounded in the fraudulent concealment of harm which

gives rise to the right to sue.‘” (quoting Aldrich v. McCulloch

Props., Inc., 627 F.2d 1036, 1043 n.7 (10th Cir. 1980));9 Aldrich, 627

F.2d at 1043 (same).

¶21 These crucial differences notwithstanding, equitable

estoppel and equitable discovery both share the need to

“evaluat[e] . . . the reasonableness of a plaintiff‘s conduct in light

of the defendant‘s fraudulent or misleading conduct.” Russell

Packard, 2005 UT 14, ¶ 26. For example, equitable estoppel

requires “reasonable action or inaction by the other party taken on

the basis of the first party‘s statement, admission, act, or failure to

act,” Jeppesen, 2018 UT App 234, ¶ 33 (emphasis added) (citation

omitted), and equitable discovery requires that “the plaintiff

neither knew nor reasonably should have known of the facts

underlying his or her cause of action” or that “a reasonably diligent

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11

plaintiff may have delayed in filing his or her complaint.” Russell

Packard, 2005 UT 14, ¶ 44 (emphases added).

¶22 It was in the context of the two doctrines’ commonality in

evaluating the reasonableness of a plaintiff‘s conduct that the

Russell Packard court noted that equitable discovery has its

“genesis in estoppel” and is “essentially a claim of equitable

estoppel.” Id. ¶ 26. Owners claim these statements in Russell

Packard effectively merged equitable estoppel into the

concealment prong of equitable discovery. Not so. We never said

or meant that equitable discovery subsumes equitable estoppel.

Rather, we were merely highlighting a similarity between the

doctrines, not conflating them. Indeed, we mentioned equitable

estoppel as a general principle to illustrate that our law seeks to

prevent defendants from unjustly relying on a statute of

limitations; we did not go into further detail as to equitable

estoppel‘s own prima facie elements. And, ultimately and

regardless, these two sentences of dicta are insufficient to defeat

established case law.

¶23 Simply put, the doctrines are distinct. Equitable discovery

may be invoked in response to a statute of limitations defense

when the plaintiff was unaware of the facts underlying a cause of

action because of the defendant‘s fraudulent concealment (absent

exceptional circumstances, see supra ¶ 16 n.3). Equitable estoppel,

however, doesn‘t require the plaintiff to be unaware of the facts

underlying a cause of action. If we were to require this, then

defendants could use dilatory tactics to stave off an action until

after a limitations period expired and then turn around and use

the statute of limitations as a defense. We will not allow a party to

take advantage of their own wrong.

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Opinion of the Court

12

B. A Mere Promise to Pay is Insufficient to Invoke the Doctrine of

Equitable Estoppel

¶24 Having clarified the distinction between equitable

estoppel and equitable discovery, we now shift our focus. Though

we‘ve established that equitable estoppel may be invoked even

when the plaintiff is aware of a cause of action, the doctrine has its

own limitations. Today we take the opportunity to clarify one of

those limitations—specifically, what it means for a “statement,

admission, act, or failure to act” to be “inconsistent with a claim

later asserted.” Jeppesen, 2018 UT App 234, ¶ 33 (citation omitted).

We clarify that a mere promise to pay, without more, is

categorically insufficient to be considered “inconsistent with a

claim later asserted” and, thus, insufficient to invoke equitable

estoppel to toll a limitations period.

¶25 The “inconsistent with a claim later asserted” language,

as articulated in Jeppesen, requires clarification. While we do not

provide a definitive list of “statement[s], admission[s], act[s], or

failure[s] to act” that are categorically “inconsistent with a claim

later asserted“—future cases will afford us the opportunity to do

so—we identify that mere promises to pay, without more, are

excluded from that list. See id. (citation omitted). We borrow this

language from an American Law Report, see Allan E. Korpela,

Promises to Settle or Perform as Estopping Reliance on Statute of

Limitations, 44 A.L.R.3d 482, 488 (1972) (stating that “a mere

promise by a defendant to pay, without more, even though relied

upon by the plaintiffs, does not justify invoking the doctrine of

equitable estoppel“), and are supported in our determination by

the reasonableness element of the equitable estoppel test and by

persuasive holdings in sister jurisdictions.

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¶26 We do not pretend to possess the foresight or imagination

to list every “statement, admission, act, or failure to act” that is

“inconsistent with a claim later asserted,” but we are comfortable

drawing a line here. In a debtor-creditor relationship, the debtor

has made an initial promise to pay before the statute of limitations

runs. This initial promise to pay alone is insufficient to estop the

defendant from asserting a statute of limitations defense—if it

were sufficient, the equitable estoppel exception would swallow

the statute of limitations defense. Put another way, if the initial

promise by a debtor to pay was sufficient to invoke the equitable

estoppel doctrine, all creditors would be eligible to estop a statute

of limitations defense upon the establishment of the debtor-

creditor relationship, thus rendering the defense (and its

exceptions) useless in this context. And given the important goals

served by statutes of limitations, such as preventing surprise,

fictitious, or fraudulent claims and stale claims that are difficult to

prosecute because of lost evidence, memories, or witnesses, Davis v. Provo City Corp., 2008 UT 59, ¶ 27, 193 P.3d 86, we are not

willing to render either the defense or its exception meaningless.

In other words, we do not find that a debtor‘s initial promise to

pay is a “statement, admission, act, or failure to act” that is

“inconsistent with a claim later asserted.”

¶27 The equitable estoppel exception to the statute of

limitations defense concerns “statement[s], admission[s], act[s], or

failure[s] to act” that are made subsequent to the initial promise to

pay. And we find that a mere promise to pay, without more, is

merely a restatement of a debtor‘s initial promise to pay and does

not indicate changed circumstances following the initial promise.

A mere reiteration of a preexisting promise, much like the initial

promise, cannot be sufficient to toll a limitations period because it

would obviate the purpose of the statute of limitations defense

and its equitable estoppel exception. As such, a mere promise to

pay, without more, even though relied upon by the plaintiff, is not

“inconsistent with a claim later asserted.”

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¶28 And while our focus is primarily on the first prong of the

equitable estoppel test, the second prong provides additional

support to our conclusion. This prong requires “reasonable action

or inaction by the other party taken on the basis of the first party‘s

statement, admission, act, or failure to act“—that is, a plaintiff

must show not only that she was induced into “action or inaction”

by the defendant‘s “statement, admission, act, or failure to act,”

but also that that her action or inaction was “reasonable.” Jeppesen, 2018 UT App 234, ¶ 33 (citation omitted). If we are to accept the

truism that “promises are made to be broken,” we can‘t imagine

that any reasonable party would accept a mere promise to pay at

face value. Thus, even if a mere promise to pay were “inconsistent

with a claim later asserted” (and it is not), the reasonableness

element of the equitable estoppel test indicates that such reliance

would be insufficient.

¶29 We are not the only court to draw this line. The principle

that a mere promise to pay, without more, is insufficient to invoke

equitable estoppel has been expressed by courts in other

jurisdictions. Georgia identified this principle as early as 1939 in

Bank of Jonesboro v. Carnes, 2 S.E.2d 495, 499 (Ga. 1939), where creditors were precluded from

using equitable estoppel to toll a statute of limitations because the

debtor merely “sat among his associates on the board of directors

and at times discussed [his debts] and stated he would pay them.”

2 S.E.2d 495, 499 (Ga. 1939). In fact, the debtor never “sought an

extension, or withdrawal of any suit, [nor was a] suit . . . ever

actually proposed or threatened. There was no agreement on his

part not to plead the statute, and no express request for

indulgence.” Id. Similarly, in Grass v. Eiker, creditors were

precluded from using equitable estoppel to toll a statute of

limitations because, when the creditors repeatedly demanded

payment, the debtor had merely replied that “he had other uses

for the money and he just couldn‘t pay.” 135 A.2d 153, 154 (D.C.

Mun. Ct. 1957). The court rejected these statements as grounds for

estoppel, stating,

[a]t most it represents a bare verbal promise to pay

the debt at a vague future time with an implied

request for forbearance on the part of [the creditor]

until [the debtor] could secure more funds. [The

debtor] never agreed to waive the statute nor did he

ask [the creditor] to refrain from bringing suit.

Id.

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¶30 And courts have continued to abide by similar limitations

more recently. A New York appellate court found that “[m]ere

promises to pay in the future . . . are insufficient to support a

theory of equitable estoppel” without evidence showing that the

debtor “intended to lull” the creditors into inaction. In re Estate of

Thomas, 124 A.D.3d 1235, 1241 (N.Y. App. Div. 2015) (quoting Erlichman v. Ventura, 271 A.D.2d 481, 481 (N.Y. App. Div. 2000)).

Connecticut courts similarly have required evidence that the

debtor “intended or calculated” inducement of inaction but

emphasized that the misrepresentation “must relate to some

present or past fact or state of things, as distinguished from mere

promises or statements as to the future. The misrepresentation

must be one of fact and not of intention to support equitable

estoppel.” Wells Fargo Bank, N.A. v. Riverview E. Windsor, LLC,

2010 WL 5610864, at *3 (Conn. Super. Ct. 2010) (citation omitted)).

And on the other side of the country, California courts have

required that the promise “be reasonably relied upon,” and will

consider, among other showings, “that a promise to pay has been

related to the happening of a specific event,” such as upon getting

“a good start in [the debtor‘s] business” or “termination of suit

against person secondarily liable.” CPI Advanced, Inc. v. Kong

Byung Woo Comm. Ind. Co., Ltd., 2003 WL 25783119, at *6 (C.D. Cal.

2003) (citations omitted), rev‘d on other grounds and remanded, 135

F. App‘x 81 (9th Cir. 2005). Though based on different grounds,

we find the conclusions drawn by our sister courts persuasive in

clarifying the limitations of the equitable estoppel doctrine. Our

clarification today is an objective determination based on

preserving the utility of the equitable estoppel exception to the

statute of limitations defense, see supra ¶ 17, and does not require

Utah courts to consider the intent of the defendant (as in New

York and Connecticut), nor does it rely solely on the

reasonableness requirement (as in California).

¶31 By way of example, this court did find more than a mere

promise to pay in Rice v. Granite School District, 456 P.2d 159 (Utah

1969). In Rice, an insurance adjuster made several promises to the

injured plaintiff over the course of a year, including advising her

that “she would be compensated,” “she would be indemnified for

her medical expenses,” “the insurance company would accept

responsibility and that she was not to worry,” and “everything

was in proper order.” Id. at 161. Rice delayed commencing action

because she was told by the insurance adjuster that her claim

couldn‘t be processed until the adjuster had ascertained the costs

FITZGERALD V. SPEARHEAD INVESTMENTS, LLC

Opinion of the Court

16

of her damages. Id. Then, abruptly after Rice‘s limitations period

to bring a suit had expired, she was told that her claim was

denied. Id. After hearing this, Rice instigated a suit to recover for

her injuries, but the insurance company filed a motion to dismiss

on the ground that her claim was barred by the one-year

limitations period. Id. at 160. Such actions by the insurer were

enough for a reasonable trier of fact to conclude that the insurance

carrier made more than a mere promise to pay. See id. at 163.

Indeed, beyond representing to Rice that it was waiting for key

information before it could file the claim, the insurance carrier

admitted liability and promised compensation upon several

occasions. Unlike the debtor in Grass, who merely said he “had

other uses for the money and he just couldn‘t pay,” the insurer

“lull[ed] [Rice] into a false sense of security,” by accepting

responsibility, promising payment, and telling Rice not to worry

and that everything was in order. Further, even the defendant in

Rice recognized that the facts involved more than a mere promise

to pay; rather, the question was “whether negotiations for the

compromise of a claim or debt will give rise to an estoppel”

defense. Id. at 163. These statements by the insurer went beyond

those of the debtor in Bank of Jonesboro, who merely stated he

would pay a debt he was already bound to pay.

¶32 In sum, a mere promise to pay—such as a bare verbal

promise to pay a debt at a vague future time with an implied

request for forbearance, or merely restating that a debt will be

paid—without more is not sufficient to invoke the doctrine of

equitable estoppel. That being said, we do not claim that this is a

complete explanation of the equitable estoppel doctrine as a

whole, particularly regarding what sufficiently constitutes a

“statement, admission, act, or failure to act . . . inconsistent with a

claim later asserted.” Future cases will present opportunities to

more fully define the contours of the equitable estoppel test.

II.

¶33 Now that we have clarified that equitable estoppel is a

discrete basis for tolling a limitations period and that a mere

promise to pay, without more, is insufficient to successfully

invoke the equitable estoppel doctrine, we turn to the case before

us. In reviewing Alpine East‘s Rule 59 Motion, the district court

relied on the court of appeals’ ruling in Jeppesen v. Bank of Utah,

2018 UT App 234, 438 P.3d 81, to determine that a material issue

of fact exists as to whether Owners’ promises reasonably induced

Alpine East to inaction under an equitable estoppel framework.

Cite as: 2021 UT 34

Opinion for of the Court

17

¶34 We‘re taking a step back from the district court‘s position.

We agree with the court that equitable estoppel is a discrete basis

for tolling a statute of limitations. But, given our primary role

today in clarifying the law, we choose to vacate its determination

and remand for further proceedings consistent with our

clarification. On remand, the district court will be in the best

position to determine in the first instance if a material issue of fact

exists as to whether Fitzgerald‘s promises constituted more than a

mere promise to pay.

CONCLUSION

¶35 Equitable estoppel protects a creditor when she has

reasonably relied on a statement or act, made by the debtor,

inconsistent with the debtor‘s later assertion of a statute of

limitations defense. We find the doctrine is a stand-alone basis,

distinct from equitable discovery, for defeating a statute of

limitations defense. However, given the nature of debt, the

doctrine‘s reasonableness requirement, and similar conclusions in

our sister jurisdictions, we also find that a mere promise to pay,

without more, even though relied upon by a party, is insufficient

to invoke equitable estoppel. As such, we vacate the district

court‘s denial of summary judgment and remand for further

proceedings in accordance with this opinion.

Notes

1
Only Alpine East Investors, LLC is before us as an appellee.
2
As this matter is before us on an appeal from a motion for summary judgment, we recite the facts and indulge reasonable inferences in the light most favorable to Alpine East, the nonmoving party. Herland v. Izatt, 2015 UT 30, ¶ 9, 345 P.3d 661.
3
The equitable discovery doctrine may be invoked in two situations: (1) where the plaintiff was unaware of the cause of action due to the defendant‘s fraudulent concealment (the “concealment prong“), and (2) when exceptional circumstances so require, regardless of any wrongdoing by the defendant. See Russell Packard Dev., Inc. v. Carson, 2005 UT 14, ¶ 25, 108 P.3d 741. This case does not address the exceptional circumstances prong. As such, and for the ease of the reader, all references to “equitable discovery” in this opinion refer to the concealment prong.
4
For our purposes, Ellul uses the term “equitable tolling” synonymously with “equitable discovery.”
5
We do not, however, intend to undermine the important purposes served by statutes of limitations, which include “preventing unfair litigation such as ‘surprise or ambush claims, fictitious and fraudulent claims, and stale claims.‘” Davis v. Provo City Corp., 2008 UT 59, ¶ 27, 193 P.3d 86 (quoting Vigos v. Mountainland Builders, Inc., 2000 UT 2, ¶ 22, 993 P.2d 207).
6
The First Circuit appears to use the term “equitable tolling” in a similar manner to our use of “equitable discovery“—both require that the plaintiff be unaware of their cause of action while “equitable estoppel” requires no such lack of knowledge. See Ramirez-Carlo, 496 F.3d at 48 n.3 (“The doctrine of equitable tolling suspends the running of the statute of limitations if a plaintiff, in the exercise of reasonable diligence, could not have discovered information essential to the suit.” (quoting González v. United States, 284 F.3d 281, 291 (1st Cir. 2002))).
7
The Eighth Circuit does differentiate between equitable tolling and equitable discovery. See supra ¶ 19 n.5. Nevertheless, like the First Circuit, the Eighth Circuit applies equitable tolling to plaintiffs who were unaware of their cause of action while “[e]quitable estoppel presupposes that the plaintiff knows of the facts underlying the cause of action.” Bell, 99 F.3d at 266 n.2.
8
The Ninth Circuit also applies equitable tolling “when the plaintiff is unaware of his cause of action, while equitable estoppel applies when a plaintiff . . . knows of his cause of action.” Stitt, 919 F.2d at 522.
9
The Eleventh Circuit appears to use equitable tolling synonymously with our equitable discovery concealment prong. As with the cases above, equitable tolling in the Eleventh Circuit requires the plaintiff to be unaware of the cause of action. See Cook, 753 F.2d at 1563.

Case Details

Case Name: Fitzgerald v. Spearhead Investments
Court Name: Utah Supreme Court
Date Published: Jul 22, 2021
Citations: 493 P.3d 644; 2021 UT 34; Case No. 20190644
Docket Number: Case No. 20190644
Court Abbreviation: Utah
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