When can public employees recover attorney fees after criminal acquittal? Christensen v. Juab School District Explained

The Utah Supreme Court’s decision in Christensen v. Juab School District provides important guidance for public employees seeking reimbursement of attorney fees and costs after successfully defending criminal charges. The case clarifies when and how Utah Code section 52-6-201’s Reimbursement Statute applies to employment-related criminal prosecutions.

Background and Facts

Hadley Christensen, a fifth-grade teacher for Juab School District, allowed a former student to attend a sleepover with his daughter during Christmas break. The sleepover was not school-sanctioned and occurred because of the student’s friendship with Christensen’s daughter. Christensen was subsequently charged with aggravated sexual abuse of a child, with the charge enhanced based on his position of special trust as the victim’s former teacher. After the trial court granted a directed verdict on key elements and the jury acquitted him, Christensen sought reimbursement for his attorney fees and costs under Utah’s Reimbursement Statute.

Key Legal Issues

The court addressed two critical questions: (1) whether the right to reimbursement attaches based on allegations within the criminal information or requires a more fact-specific inquiry into actual events, and (2) the scope of reimbursement when appropriate. Only the first issue was decided, as the parties had stipulated to the amount.

Court’s Analysis and Holding

The Utah Supreme Court affirmed the district court’s grant of partial summary judgment, following its precedent in Acor v. Salt Lake City School District. The court emphasized that under the “under color of authority” prong of the Reimbursement Statute, the analysis focuses on the allegations in the criminal information, not the underlying factual circumstances. Because Christensen was charged as someone in a position of special trust—requiring both a position of authority and the ability to exercise undue influence—the criminal information satisfied the statute’s requirements regardless of whether he actually used his position inappropriately.

Practice Implications

This decision reinforces that public employees can recover attorney fees under Utah’s Reimbursement Statute even when criminal charges are ultimately proven baseless. The ruling protects employees from bearing the costs of defending against employment-related criminal allegations, encouraging the proper performance of public duties without fear of personal financial ruin from unfounded prosecutions. For practitioners, the case emphasizes focusing on the allegations themselves rather than attempting to relitigate the underlying facts when seeking reimbursement.