Park City v. Woodham
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In the case at hand, Robert Evan Woodham was convicted for failing to yield to stationary emergency vehicles in violation of Utah Code subsection 41-6a-904(2). The conviction was upheld by the district court, after which Woodham appealed to the Utah Court of Appeals. However, the appellate court dismissed his appeal for lack of jurisdiction, citing that the district court did not rule on the constitutionality of a statute or ordinance, which is a requirement for appellate review under Utah Code § 78A-7-118(11). Woodham then petitioned the Supreme Court of Utah, arguing the district court implicitly ruled on his constitutional argument.
The Supreme Court of Utah clarified that an implicit ruling by the district court on the constitutionality of a statute or ordinance is sufficient to permit appellate review under Utah Code subsection 78A-7-118(11), overruling a contrary holding by the Utah Court of Appeals in Murray City v. Timmerman. However, the Court agreed with the appellate court's decision in Woodham's case, stating that he did not preserve a constitutional challenge to the emergency vehicle statute, and therefore, the district court did not implicitly rule on its constitutionality. Consequently, the dismissal of Woodham's appeal due to lack of jurisdiction was affirmed.
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