Luna v. Luna
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The Supreme Court reversed the decision of the court of appeals affirming the order of the district court granting summary judgment in favor of Maria Luna on Luis Luna's negligence claim, holding that the court of appeals improperly adopted the judicial admission doctrine as applied to a party's deposition testimony.
Luis was a passenger in his sister Maria's car when it collided with a vehicle driven by Antonio Arias in a Salt Lake City intersection. Luis sued Maria and Antonio. Maria moved for summary judgment based in part on Luis's testimony that Maria had entered the intersection on a green light. Luis sought to introduce Antonio's testimony that he had the green light, but the district court refused to allow Luis to create a genuine issue of material fact by introducing evidence contradicting his own sworn deposition testimony. The district court granted summary judgment for Maria. The court of appeals affirmed, concluding that Luis's statement should be considered a judicial admission not capable of being rebutted by other evidence. The Supreme Court reversed and remanded the case for further proceedings, holding that a party's deposition testimony is like any other evidentiary admission and can be contradicted with other credible evidence.
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