Grillone v. POST
Grillone v. POST, 2025 UT 7 (Hagen, J.)
Civil/Admin
The Utah Supreme Court held:
- The Utah Court of Appeals correctly declined to disturb POST’s three-year suspension of Grillone’s certification because civil statutes of limitation do not apply to POST proceedings.
- Practice tip: A civil statute of limitations does not apply to administrative disciplinary proceedings absent statutory language to the contrary.
- Practice tip: The statutory language designating POST proceedings as “civil actions” does not incorporate the civil limitation periods but rather distinguishes those proceedings from criminal actions.