Lewis v. US Bank Trust
Lewis v. US Bank Trust, 2020 UT App 55 (Hagen, J.)
A property owner sued a bank for quiet title to a property and unjust enrichment. The bank moved to dismiss the complaint for failure to state a claim under Utah R. Civ. P. 12(b)(6) because the owner’s claims were barred by claim preclusion by a prior federal case the owner had brought. The bank attached to its motion a variety of property and legal documents; it did not, however, attach the federal complaint or ask the court to take judicial notice of the federal complaint. The district court granted the bank’s motion to dismiss the complaint. The Utah Court of Appeals reversed, holding:
- Because the district court had to consider documents outside of the complaint to decide whether the bank had met the test for claim preclusion, the district court erred when it granted the bank’s motion to dismiss for failure to state a claim. The district court should have converted the motion to one for summary judgment and allowed the parties a reasonable opportunity to present evidence in accordance with the summary judgment rules.