Segota v. Young Chrysler, 2020 UT App 105 (July 9, 2020)

Segota, dissatisfied with his truck purchase, sued the dealership and the dealership’s bond company, alleging breach of contract and fraud. But he failed to serve initial disclosures or conduct any discovery, prompting a flurry of summary judgment motions from the defendants after the close of fact discovery. Though Segota’s counsel challenged these motions as “feckless,” the trial court granted them and dismissed his claims. The Utah Court of Appeals affirmed, holding that the trial court did not abuse its discretion in denying Segota’s tardy request for extension of fact discovery or in penalizing him under Utah R. Civ. P. 26(d)(4) for failure to make timely initial disclosures. Thus, “feckless” or not, dismissal of Segota’s claims was appropriate.