Family Law Appeals
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Christensen v. Christensen
July 9, 2026
A district court enforcing a divorce decree need not require a petition to modify when relief falls within the decree’s four corners, but rule 108 mandates an evidentiary hearing upon request in enforcement proceedings and requires independent—not deferential—review of a commissioner’s recommendation.- Civil Appeals
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- Family Law Appeals
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- Utah Court of Appeals
When does a divorce decree modification become ambiguous on mortgage obligations?Schmidt v. Schmidt
July 2, 2026
When two judicial officers each adopt a different ‘unambiguous’ interpretation of the same divorce decree provision, that divergence is itself a strong signal of ambiguity requiring extrinsic evidence.- Civil Appeals
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- Family Law Appeals
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- Utah Court of Appeals
When does a threatening text message justify a protective order in Utah?Canteros-Alvarez v. Green
June 19, 2026
A conditional, anger-fueled text message threatening physical harm only if the recipient strikes first does not establish the ‘imminent physical harm’ required for a protective order under Utah’s Cohabitant Abuse Act.- Civil Appeals
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- Family Law Appeals
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- Utah Court of Appeals
Can ineffective assistance of counsel reverse a termination of parental rights order?In re A.H.
June 4, 2026
The court established that attorneys’ ineffective assistance in termination proceedings can occur when counsel fails to file basic pretrial disclosures and present expert testimony on critical issues like sibling bonds and adoption trauma.- Family Law Appeals
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Jenkins v. Jenkins
May 29, 2026
This decision clarifies that trial courts retain broad discretion to make fault-based adjustments to alimony awards even when insufficient funds exist to meet both parties’ needs.- Family Law Appeals
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Slaughter v. Alleman
May 29, 2026
Utah divorce decrees create final property divisions that survive a spouse’s death, regardless of whether performance obligations are completed.- Family Law Appeals


