Rhen v. Christensen, 2017 UT App 21 (Feb. 2, 2017)

The defendant challenged the district court’s grant of summary judgment to the plaintiff on the first two elements of his slander of title claim—publication of a slanderous statement disparaging the claimant’s title and that the statement was false.  The defendant claimed, among other things, that he had a valid attorney’s lien on the plaintiff’s property.  The court affirmed the district court’s holding that the defendant attorney did not have a valid statutory attorney’s lien.  It explained, “An attorney’s single comment concerning property not at issue in the divorce and not owned by the client, made in the course of performing extensive divorce-related work for the client, is too tenuous to connect the legal work to the Property.”