Davis County v. Purdue Pharma
Davis County v. Purdue Pharma, 2020 UT 17 (Lee, A.C.J.)
Local governments filed suits against the opioid manufacturers in several judicial districts across Utah. The first suit was filed in the third district. Davis County then filed suit in the second district. A manufacturer filed a motion in the second district asking the court to transfer the case to the third district for discovery and pretrial proceedings. The district court agreed. On interlocutory appeal, the Utah Supreme Court affirmed, holding:
- The multi-district transfer of a case from the second district to the third district cannot be authorized by Utah R. Civ. P. 42, which involves consolidation of cases within a single judicial district.
- The multi-district transfer of a case from the second district to the third district cannot be authorized by Utah Code § 78B-3-309, the venue statute that applies to trial. But that venue statute does not displace the inherent power of the courts to transfer venue for other purposes. The venue statute does not mention pre-trial proceedings, and that gap is just a gap and not a field-occupying omission barring the exercise of inherent judicial power.
- Courts have inherent judicial power to manage court proceedings in a manner that promotes efficiency in the judicial process, which includes transferring a case from one district to another.
- The district court did not abuse its discretion in granting the motion to transfer the case to the third district. The court cited a broad range of judicial economy considerations, and although Davis County has fair points of concern about the multi-district litigation, the district court did not exceed the bounds of its discretion when transferring the case.
2020, Civil, Q2, Supreme Court