Griffin v. Snow Christensen & Martineau
Griffin v. Snow Christensen & Martineau, 2020 UT 33 (Petersen, J.)
Procedure
Ron Griffin brought a malpractice claim against Snow Christensen & Martineau (SCM). SCM moved to dismiss the complaint. The court granted the motion and signed the proposed dismissal order (April 10 Order). Griffin subsequently filed a post-judgment motion for relief, and SCM argued that the motion was not timely because it was filed more than 28 days after the April 10 Order. The district court concluded that the April 10 Order was not a separate judgment under rule 58(a) of the Utah Rules of Civil Procedure and therefore did not start the time to file post-judgment motions. The court considered and granted Griffin’s motion, and SCM petitioned for an interlocutory appeal. The Utah Supreme Court affirmed, holding:
- The time to file post-judgment motions or a notice of appeal is triggered by entry of judgment under rule 58A. The rule requires “a separate document ordinarily titled ‘Judgment’—or, as appropriate, ‘Decree,” which must be self-contained and independent from any other document, including the decision that gave rise to it. Such a judgment signals at the case level that all claims have been resolved, documents the resolution of each claim, and starts the clock running for post-judgment motions and appeal.
- If the court does not enter a separate judgment under rule 58(a), the entry of judgment does not take place until “150 days have run from the clerk recording the decision, however designated, that provides the basis for the entry of judgment.” Utah R. Civ. P 58A(e)(2)(B).
- The April 10 Order in this case was not a final judgment because it was named “Order of Dismissal with Prejudice” rather than “Judgment,” and because it was the order confirming the court’s ruling, not a separate judgment documenting the resolution of the claims in the district court. Accordingly, judgment was not final until 150 days from the April 10 Order, and Griffin’s post-trial motions were therefore timely.