Green River Canal Co. v. Olds
In Green River Canal Co. v. Olds, 2004 UT 106, P 43, 110 P.3d 666, the Court discovered in rule 4(e) of our Rules of Appellate Procedure, the rule governing extensions of time to file appeals, a workable standard that could be transferred to the task before us.
Rule 4(e) grants a court discretion to extend the time for filing a notice of appeal when a late filing is the product of excusable neglect or when good cause is present.
The Court interpreted good cause to be a "special circumstance" that was beyond the party's control. Id.