Griffin v. Snow Christensen & Martineau, 2020 UT 33 (June 10, 2020)

The court held the plaintiff’s post-trial motions were timely because the district court’s order granting a motion to dismiss plaintiff’s complaint with prejudice was not a separate Rule 58(a) judgment, and therefore did not trigger the 28-day deadline for plaintiff to file post-trial motions.  Although the order was separate from the court’s oral ruling and accompanying minute entry, it was not separate from the court’s decision on the relevant motion, clearly identified as a judgment, and limited only to information relevant to a judgment.  The court further held that plaintiff’s acknowledgment of the order as a Rule 58(a) judgment in his pleadings before the district court did not constitute a waiver of the issue, because Rule 58(a) must be applied mechanically to determine the issue of timeliness.