The Appellate Group

Taylor v. Lawlor

Taylor v. Lawlor, 2026 UT App 118 (Harris, J.)

Civil

The Utah Court of Appeals held:

A district court exceeds its authority when it strikes or rejects a memorandum based on a formatting issue under rule 37 of the Utah Rules of Civil Procedure, which applies only to situations involving discovery orders.

Judicial tip:

Rule 10(f) of the Utah Rules of Civil Procedure expressly precludes any fatal effect or terminating sanction based solely on a formatting error, such as single-spacing the filing.

Judicial tip:

ASanctions should not be imposed for formatting problems unless the court has expressly identified the specific formatting problem and the party willfully refused to fix it.

Judicial tip:

If a party improperly includes a motion for affirmative relief in an opposing or reply memorandum, the proper recourse is for the court to ignore the improper request, not to strike the entire memorandum.

Read the full court opinion

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2026, Civil, Court of Appeals, Q3
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