Cottage Capital, LLC v. Red Ledges Land Dev., 2015 UT 27 (Jan. 30, 2015) 

The district court dismissed this case involving enforcement of a guarantee agreement, concluding that it should have been asserted as a compulsory counterclaim in an earlier suit between the parties. The Utah Supreme Court reversed, holding that Rule 13(a) of the Utah Rules of Civil Procedure does not extend to a counterclaim that has not yet matured at the time of a civil proceeding.