Kaiserman Associates, Inc. v. Francis Town

ZIMMERMAN, Justice,

dissenting:

Because I disagree with the lengths to which the majority goes to rescue Mr. Marti-neau from this second documented instance of sloppy legal work in this case, I dissent.

This case is before us only because Mr. Martineau failed to do even minimal legal research before garnishing Francis Town’s assets. If one simply looks in the index to the Utah Code Ann. under “Garnishment,” one comes to the subheading “Governmental immunity.” Beneath that entry it states, “Governmental entities exempt from, § 63-30-22.” Even without looking to the actual statute, basic legal research illustrates that governmental entities are exempt from garnishment proceedings. It may be the case, as Mr. Martineau argues, that the governmental immunity from garnishment is little-known. This is especially true for attorneys who have done no research, and as the majority acknowledges, the fact that the statute is not common knowledge is no excuse for failing to conduct the basic research which would reveal its existence.

Seeking to undo the sanctions imposed for this shoddy work, Mr. Martineau filed a brief with this court in which he states that a garnishment is not a pleading subject to rule 11 sanctions. Having said that, he fails to provide argument or research to support the contention. Nonetheless, the majority culls this one statement from the brief, does the rather elementary research needed to determine that it is a correct statement of the law, and proceeds to make it the basis for its decision. The court justifies doing Mr. Mar-tineau’s work for him by stating that “[i]n our view, an overlooked or abandoned argument should not compel an erroneous result. We should not be forced to ignore the law just because the parties have not raised or pursued obvious arguments.” I believe that this is not a correct statement of our usual practice, and I see no justification for abandoning our usual practice in this case.

We regularly decline to do precisely what the majority does in this case. For example, in American Towers Owners Ass’n, Inc. v. CCI Mechanical Inc., 930 P.2d 1182 (Utah 1996), Justice Howe himself stated: “Issues not briefed by an appellant are deemed waived and abandoned.” Id. at 1185 n. 5 (citing Pixton v. State Farm Mut. Auto. Ins. Co., 809 P.2d 746, 751 (Utah Ct.App.1991)). In Walker v. U.S. Gen., Inc., 916 P.2d 903, 908 (Utah 1996), we stated: “Inasmuch as [appellant] has failed to properly brief this argument, we decline to address its merits.... ‘A brief must contain some support for each contention.’ [Appellant’s] briefs wholly fail to cite to the record or a single case in support of this contention. We therefore do not address it.” Id. at 908 (quoting State v. Wareham, 772 P.2d 960, 966 (Utah 1989)). Furthermore, as we stated in State v. Bishop, 753 P.2d 439 (Utah 1988), a “reviewing court is entitled to have the issues clearly defined with pertinent authority cited and is not simply a depository in which the appealing party may dump the burden of argument and research.” Id. at 450 (quoting Williamson v. Opsahl, 92 Ill.App.3d 1087, 48 Ill.Dec. 510, 416 N.E.2d 783, 784 (1981)).

Our cases do not suggest that we follow this practice only when the unbriefed argument is not obvious. In fact, in my opinion, we should follow it even more strictly where the argument is obvious, as the failure to brief the issue most likely illustrates that the attorney has failed to perform basic legal research. That makes particular sense here, where the client and the attorney are one and no harm will befall an innocent third party.

Thus, while I agree that under the old version of rule 11 the district court erred in imposing sanctions (although it could impose them under the current rale), I do not believe there are any compelling circumstances here which should lead us to depart from the well-established principle that we will not address, or base a decision on, issues which have not been adequately briefed. The majority’s discussion of the old rule 11 is cor*467rect. But I would not give Mr. Martineau the benefit of it.