Fitzgerald v. Spearhead Investments, 2021 UT 34 (July 22, 2021)

In this interlocutory appeal, the supreme court held that equitable estoppel may be invoked as a stand-alone basis for tolling a statute of limitations. It explained this is a doctrine distinct from equitable tolling. “[E]quitable estoppel is invoked in cases where the plaintiff knew of the existence of his cause of action but the defendant’s conduct caused him to delay in bringing suit, and  equitable discovery is invoked in cases where the plaintiff is ignorant of his cause of action because of the defendant’s fraudulent concealment.”