Court Opinions: 10th Circuit Court of Appeals Opinions for May 1

The 10th Circuit Court of Appeals

Editor’s Note: Law Week Colorado edits court opinion summaries for style and, when necessary, length.

Hatfield v. Cottages on 78th Community, et al.


Wendi Hatfield is a homeowner in The Cottages on 78th, a planned unit development in Midvale, Utah. The development is governed by The Cottages on 78th Community Association, or the homeowners association, of which Matthew Medford was a member. The HOA acts through a five-member management committee.

Beginning in August 2016, Hatfield exhibited behavioral issues. She allegedly surveilled homeowners, drove recklessly through the community, made unsubstantiated claims against neighbors and acted aggressively toward neighbors and the committee. 

As a result, the committee drafted and sent a warning letter to Hatfield in April 2019. Two days later, Hatfield responded to the warning letter through her attorney. She denied the allegations, demanded the committee withdraw its warnings and made an extensive records request.

Seeing no change in her behavior, the committee — in August 2019 — fined and assessed Hatfield $2,231.25 for continued violations of the HOA’s rules. In response, Hatfield filed a complaint with the Utah Antidiscrimination and Labor Division, alleging the HOA violated the Utah Fair Housing Act by engaging in religious discrimination and retaliation

Two days later, Hatfield filed a small-claims complaint against the HOA alleging it had commenced and prosecuted a groundless and improper enforcement action, causing her to incur attorney fees.

In November 2019, Hatfield voluntarily withdrew her UALD and small claims complaints. Then in December 2019, she filed a federal complaint with the U.S. District Court for the District of Utah, asserting five claims. Alleging retaliation in violation of the FHA, invasion of privacy, defamation, tortious interference with economic relations and civil conspiracy.

In April 2020, the district court dismissed Hatfield’s claim for tortious interference and civil conspiracy. On March 21, the district court granted the defendants’ motion for judgment on the pleadings on the rest of Harifield’s claims. The defendants then moved for attorneys’ fees, which the district awarded. The district court determined Hatfield’s claims were frivolous and groundless at the outset. The court ordered Hatfield’s counsel to show cause why he shouldn’t be sanctioned under Rule 11 of the Federal Rules of Civil Procedure. 

Hatfield appealed for four reasons. First, she argued the district court abused its discretion in awarding attorneys’ fees and that her retaliation claim wasn’t frivolous. Second, she contended the district court abused its discretion by determining the amount of attorneys’ fees. Third, she claimed the court erred in ordering her counsel to show cause why he shouldn’t be sanctioned and fourth, she requested a new judge. 

A 10th Circuit Court of Appeals panel out of Salt Lake City, Utah, ruled the district court didn’t err in any of its decisions. The 10th Circuit affirmed the district court’s decision and dismissed Hatfield’s appeal of the district court’s Rule 11 Show Cause Order for lack of jurisdiction since it’s not a final appealable order and denied the request for a new judge as moot, as there is no ground for a determination of remand.

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