Utah County v. Baxter
In Utah County v. Baxter, 635 P.2d 61, 64 (Utah 1981), Utah County sought an injunction against a private individual for violation of a zoning ordinance.
The Court reasoned under the facts of that case that because a violation of a zoning ordinance is also a crime, "a showing that the zoning ordinance has been violated is tantamount to a showing of irreparable injury . . . to the public." Baxter, 635 P.2d at 64-65.
The Court therefore held that Utah County was not required to make a specific showing of irreparable injury. See id.
The legislature codified that holding in its 1991 amendment to section 17-27-1002, which provides that "[a county need only establish the violation of a zoning ordinance to obtain the injunction." Utah Code Ann. 17-27-1002(1)(b) (1999).