CFD Payson, LLC v. Christensen, 2015 UT App 251 (Oct. 8, 2015)

A divorce decree, which awarded wife one-half of the proceeds from a sale of land owned by an LLC, did not give wife a vested ownership in the land sufficient to support an attorney’s lien, because (a) neither the defendant nor spouse had a personal ownership interest in property owned by an LLC under the Act in effect, and (b) while the land was not subject to division in the divorce decree, even though proceeds from the sale of the property could be subject to distribution.