American Tierra Corp. v. City of W. Jordan
In American Tierra Corp. v. City of W. Jordan, 840 P.2d 757 (Utah 1992), the Court updated the framework for determining statute of limitations issues in Utah.
There, the Court stated that the four-year catch-all statute of limitations applies to all causes of action, legal or equitable, "in which affirmative relief is sought" and another "more specific" statute of limitations does not apply. Id. at 760.