Do postjudgment motions to reconsider toll Utah appeal deadlines? Gillett v. Price Explained

In a landmark decision that fundamentally changed Utah appellate practice, the Utah Supreme Court in Gillett v. Price definitively rejected the practice of filing postjudgment motions to reconsider and warned that such motions would no longer toll appeal deadlines.

Background and Facts

The case arose from a contract dispute where the district court granted summary judgment for defendant on statute of limitations grounds. After the court issued its memorandum decision but before entering final judgment, plaintiffs filed a “Motion for Reconsideration” challenging the court’s reasoning. The district court denied the motion, and plaintiffs filed their notice of appeal nearly two months after the final order. The Utah Court of Appeals held the appeal was untimely because it was filed more than thirty days after final judgment.

Key Legal Issues

The central question was whether a postjudgment motion for reconsideration constitutes a proper postjudgment motion that tolls the thirty-day appeal period under Rule 4(b) of the Utah Rules of Appellate Procedure. Rule 4(b) only recognizes specific motions that toll appeal deadlines, including motions under Rules 50(b), 52(b), and 59 of the Utah Rules of Civil Procedure.

Court’s Analysis and Holding

The Court held that postjudgment motions to reconsider are not sanctioned anywhere in the Utah Rules of Civil Procedure or Appellate Procedure and therefore cannot toll appeal deadlines under any circumstances. The Court explicitly rejected previous case law that had treated motions to reconsider as rule-sanctioned motions based on their substance rather than their form. The Court emphasized that “the form of a motion does matter” because it directs courts and litigants to specific, available relief under the rules.

Practice Implications

This decision requires practitioners to identify specific grounds for postjudgment relief and file motions under recognized rules. The Court warned that future filings of postjudgment motions to reconsider “may subject attorneys to malpractice claims.” Attorneys must now turn to the rules to determine whether relief exists and direct courts to specific available relief, rather than filing generic motions to reconsider.