Boyle v. Clyde Snow & Sessions PC, 2016 UT App 114 (May 26, 2016)

The plaintiff was represented by a lawyer who worked for two different law firms while the case was pending. After the lawyer switched firms, the first firm asserted a lien on a portion of the settlement funds by filing a notice of lien. However, the firm never moved to intervene in the action. After the case settled, the firm objected to dismissal until its lien issues were resolved. The court entertained motions from both firms and the lawyer, and ultimately awarded a portion of the funds to the firm. The Court of Appeals reversed, concluding that the district court lacked jurisdiction to make orders with regard to these post-judgment motions brought by non-parties in the underlying case.