Can Utah courts resolve disputed facts in extraordinary relief petitions? Carpenter v. Riverton City Explained

In Carpenter v. Riverton City, the Utah Supreme Court addressed the procedural limitations governing extraordinary relief petitions when material facts remain in dispute, providing important guidance for practitioners seeking such relief.

Background and Facts: Citizens collected signatures for a referendum to repeal Riverton City’s zoning ordinance adopting the “Hamilton Properties Specific Plan.” After significant public opposition, the city council repealed the original ordinance and enacted four new ordinances covering the same land tracts. The city recorder refused to place the referendum on the ballot, claiming it was moot due to the repeal. Citizens filed a petition for extraordinary relief seeking to apply their referendum to the new ordinances.

Key Legal Issues: The central question was whether the Utah Supreme Court could adjudicate a petition for extraordinary relief when the parties disputed the city council’s motivations for repealing and replacing the challenged ordinance. Petitioners claimed the city acted in bad faith to circumvent referendum rights, while the city argued legitimate procedural and substantive reasons justified their actions.

Court’s Analysis and Holding: The court emphasized that extraordinary relief is discretionary and limited to cases with no other adequate remedy. Critically, the court explained that determining whether to grant such relief “is not unlike a district court’s decision to grant summary judgment.” The court can only issue relief based on uncontroverted material facts established through stipulation or unopposed affidavits. Because the parties disputed the city council’s motivations—the key factual issue under the governing good faith standard—the court dismissed the petition.

Practice Implications: This decision establishes that Utah’s Supreme Court will not conduct evidentiary hearings in extraordinary relief proceedings. Practitioners must ensure all material facts supporting their petition are undisputed before filing. The court’s analogy to summary judgment standards provides a useful framework for evaluating whether extraordinary relief is appropriate, particularly in politically charged municipal law disputes involving referendum rights.