What constitutes adequate disclosure of damages computation under Utah Rule 26? Williams v. Anderson Explained

In Williams v. Anderson, the Utah Court of Appeals addressed a critical discovery question: what constitutes an adequate “computation of damages” under Utah Rule of Civil Procedure 26(a)(1)(C)? The decision provides important guidance for practitioners on how to properly disclose damages calculations in initial disclosures.

Background and Facts

Williams alleged that his former business partners wrongfully terminated his 30% ownership interest in Fix A Phone LLC before selling the company to Tricked Out Services for $200,000. In his initial disclosures, Williams stated he was “entitled to 30% of the price Tricked Out Services, Inc., paid for Fix A Phone.” The defendants moved in limine to exclude damages evidence, arguing Williams failed to provide a proper computation of damages as required by Rule 26, offering only a “formula” rather than a concrete calculation.

Key Legal Issues

The central issue was whether Williams’s disclosure satisfied Rule 26(a)(1)(C)’s requirement for “a computation of any damages claimed.” The defendants argued that Williams provided merely an algebraic formulation (“30% of x”) without defining the variable, while Williams contended that defendants knew the purchase price and could easily calculate 30% of $200,000.

Court’s Analysis and Holding

The Court of Appeals reversed the district court’s motion in limine grant. The court distinguished this case from Sleepy Holdings LLC v. Mountain West Title, noting that unlike a mere reference to a contract price untethered to any damages theory, Williams’s disclosure “described the precise components he intended to factor into his damages claim.” The court emphasized that Williams’s disclosure revealed both “the fact of damages and the method by which those damages would be calculated.” Since defendants knew the $200,000 purchase price and could readily calculate 30% as $60,000, the disclosure satisfied Rule 26’s requirements.

Practice Implications

This decision clarifies that initial disclosures need not always contain precise dollar amounts to satisfy Rule 26(a)(1)(C). When damages can be calculated from known information available to opposing parties, disclosing the method of calculation may suffice. However, practitioners should be cautious about relying solely on percentage formulas—the key is ensuring the opposing party has sufficient information to understand both the fact and extent of claimed damages. The decision also reinforces the importance of clearly articulating damage theories rather than making vague references to contractual amounts.