McKitrick v. Gibson, 2021 UT 48 (Aug. 19, 2021)

Gibson, a former county commissioner, petitioned for judicial review of Ogden City’s decision to publicly release records of an investigation into his alleged official misconduct. Though he lacked standing under GRAMA to challenge the decision, the district court permitted Gibson’s petition to go forward because he had a privacy interest in the records and therefore had traditional standing to seek review of the decision. As a matter of first impression, the Utah Supreme Court reversed the district court and remanded for dismissal of Gibson’s petition, holding that a “statutory claimant must have statutory standing, and the presence of traditional or alternative standing will not cure a statutory standing deficiency.”