The Appellate Group

Park City v. Woodham

Park City v. Woodham, 2024 UT 3 (Pohlman, J.)

Statutory Interpretation

Park City cited a driver for failing to yield to stationary emergency vehicles in violation of Utah Code subsection 41-6a-904(2). The justice court found the driver guilty, and he appealed to this district court. He then appealed to the district court. The court of appeals dismissed the case for lack of jurisdiction, stating that the statute governing cases that originate in justice court permits appellate review if the district court ruled on the constitutionality of a statute or ordinance—something which did not occur in this case. The Utah Supreme Court affirmed, holding:

  • The district court did not make any ruling—implied or otherwise—about the constitutionality of the emergency vehicle statute. Therefore, the court of appeals correctly dismissed the case for lack of jurisdiction.
  • Practice tip: The Supreme Court disavowed an earlier court of appeals opinion stating that a district court’s implied ruling rejecting a challenge to the constitutionality of a statute is insufficient to confer jurisdiction under Utah Code subsection 78A-7-118(11). Thus, appellate courts may review cases that originate in the justice court if the district court impliedly rules on the constitutionality of a statute or ordinance.

Read the full court opinion