Utah Supreme Court
Can organizations seek relief on behalf of all Utah inmates without traditional standing? ACLU of Utah v. State Explained
Summary
The ACLU of Utah, Disability Law Center, and Utah Association of Criminal Defense Attorneys petitioned for extraordinary relief on behalf of all individuals in criminal custody at risk of contracting COVID-19. The Utah Supreme Court dismissed the petition, finding that petitioners lacked standing because they failed to meet the burden of demonstrating that their issues were unlikely to be raised by others with proper standing.
Practice Areas & Topics
Analysis
In ACLU of Utah v. State, the Utah Supreme Court addressed whether organizations could obtain extraordinary relief on behalf of all individuals in criminal custody at risk of contracting COVID-19, even without traditional standing requirements.
Background and Facts: The ACLU of Utah Foundation, Disability Law Center, and Utah Association of Criminal Defense Attorneys filed a petition for extraordinary relief seeking protection for all individuals in criminal custody throughout Utah who were at risk of contracting COVID-19. Notably, no individual inmate was named as a petitioner in the case.
Key Legal Issues: The central question was whether petitioners had standing to bring their claims. Petitioners did not claim traditional standing (requiring a distinct and palpable injury giving a personal stake in the outcome) or associational standing (where an association’s members have standing). Instead, they argued they possessed public interest standing.
Court’s Analysis and Holding: The Court noted that two justices had previously expressed doubt about the intellectual underpinnings of the public interest standing doctrine. However, rather than engaging in an extended analysis of the doctrine itself, the Court focused on petitioners’ failure to meet their burden. To qualify for public interest standing, petitioners must demonstrate that the issues they seek to litigate are “unlikely to be raised” if they are denied standing. The Court found petitioners failed to meet this burden and dismissed the petition.
Practice Implications: This decision reinforces that organizations seeking public interest standing must affirmatively prove their unique position to raise particular issues. The ruling suggests Utah courts may be increasingly skeptical of public interest standing claims, particularly where affected parties could potentially bring their own challenges. Practitioners should carefully consider whether clients with traditional standing exist before pursuing public interest theories in extraordinary relief cases.
Case Details
Case Name
ACLU of Utah v. State
Citation
2020 UT 31
Court
Utah Supreme Court
Case Number
No. 20200281
Date Decided
May 21, 2020
Outcome
Dismissed
Holding
Petitioners lacked standing to seek extraordinary relief on behalf of all inmates at risk of contracting COVID-19 because they failed to demonstrate that the issues they sought to litigate were unlikely to be raised if they were denied standing.
Standard of Review
Not applicable – petition for extraordinary relief dismissed for lack of standing
Practice Tip
When seeking public interest standing, practitioners must affirmatively demonstrate that the issues they seek to litigate are unlikely to be raised by parties with traditional standing.
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