Dipoma v. McPhie
In Dipoma v. McPhie, 2001 UT 61, 29 P.3d 1225, the Court considered rule 3 of the Utah Rules of Civil Procedure, which stated that "'a civil action is commenced . . . by filing a complaint with the court'" and included cross-references to statutory fee requirements. (quoting Utah R. Civ. P. 3(a) (amended 2003)).
The Court held that because "any express reference to filing fees as a jurisdictional requirement is notably absent" from the plain language of the rule, a trial court's jurisdiction does not depend on payment of such fees. Id.