United States Fuel Co. v. Huntington-Cleveland Irrigation Co
In United States Fuel Co. v. Huntington-Cleveland Irrigation Co., 2003 UT 49, 79 P.3d 945, the Court held that a district court sitting outside the general adjudication must refrain from exercising jurisdiction over a dispute between participants in the general adjudication when the outside claim is based on contentions made in an untimely objection filed in the general adjudication.
In fact, United States Fuel contains dicta that suggests the conclusion we reach today:
"Unless and until United States Fuel sought and obtained leave of court in the general adjudication to excuse its tardy objection, the defendant was entitled to judgment perfecting the state engineer's proposed determination." Id.
The Court went on to state that "to this day, United States Fuel has not sought to have its untimely objection accepted in the general adjudication." Id.
Thus, in United States Fuel the Court held only that a court outside the general adjudication is denied jurisdiction over claims related to an untimely objection; we did not directly address whether the district court overseeing the general adjudication was denied jurisdiction and, in fact, implied that the general adjudication court would have jurisdiction.