Halversen v. Allstate Prop. & Cas. Ins. Co., 2021 UT App 59 (June 4, 2021)

The court held that Utah’s underinsured motorist statute, Utah Code § 31A-22-305.3, allows either party, within 20 days of service of the arbitration award, to request a trial de novo for any reason. The court rejected the insurance company’s argument that a trial de novo could only be granted when an arbitration award was procured by corruption, fraud, or other undue means, which was based upon the legislature’s deletion of a connecting conjunction in a revision to the statute in 2011.