The Utah Supreme Court issued opinion 2025 UT 55 in *Christensen v. Labor Commission*, a complex employment dispute involving Theresa Christensen, Salt Lake County, and the Utah Labor Commission that centers on anti-discrimination law and workers' compensation procedures.
Justice Petersen authored the court's opinion, in which Chief Justice Durrant, Associate Chief Justice Pearce, Justice Hagen, and District Court Judge John J. Nielsen joined. Justice Pohlman recused herself from the case, requiring the participation of a district court judge under Utah's judicial substitution procedures.
The case originated from Christensen's lawsuit against her former employer, Salt Lake County, under the Utah Antidiscrimination Act. Christensen alleged that the County retaliated against her after she complained that her supervisor was sexually harassing her. The dispute involved multiple claims beyond the retaliation allegation, creating a complex factual and legal framework for the court's review.
The Labor Commission Appeals Board initially ruled in Christensen's favor on the central retaliation claim. The Board concluded that Christensen had proven Salt Lake County retaliated against her following her sexual harassment complaint. As a result, the Board awarded her compensation for certain damages she had suffered due to the County's retaliatory actions.
However, the Board denied Christensen's request for statutory attorney fees. The Board's decision on attorney fees was influenced by the Utah Supreme Court's opinion in *Injured Workers Ass'n of Utah v. State*, though the complete reasoning for this denial was not fully detailed in the available portions of the opinion.
The case proceeded through Utah's appellate system, reaching the Utah Court of Appeals before arriving at the state's highest court on certiorari review. The Supreme Court heard oral arguments on Jan. 13, 2025, and issued its final opinion on Nov. 13, 2025.
The multi-party nature of the case reflects the complex procedural posture common in employment disputes involving state agencies. Christensen served as both respondent and cross-petitioner, while Salt Lake County acted as petitioner and cross-respondent. The Utah Labor Commission participated as a respondent, representing the administrative agency's interests in the appeal.
Representing Christensen was Russell T. Monahan of Salt Lake City. Salt Lake County's legal team included District Attorney Sim Gill, along with William G. Garbina and Joshua K. Peterman, also from Salt Lake City. The Utah Labor Commission was represented by the Utah Attorney General's office, including Derek E. Brown, Scott Higley, Erin T. Middleton, and Steve Geary.
The case carries significance for Utah employment law, particularly regarding the intersection of anti-discrimination protections and workers' compensation procedures. The Utah Antidiscrimination Act provides important protections for employees who report workplace harassment or discrimination, and cases like *Christensen* help define the scope and enforcement of these protections.
The Supreme Court's decision to grant certiorari review indicates the case raised important questions of state law warranting the high court's attention. Given the involvement of a major Utah county as the employer and the Utah Labor Commission as the administrative agency, the case likely addresses issues with broader implications for public sector employment practices throughout the state.
The opinion's citation as 2025 UT 55 places it among the Utah Supreme Court's significant decisions for the year, and its subject matter revision clause indicates it will be published in the Pacific Reporter, ensuring its precedential value for future employment discrimination cases in Utah.
For public sector employees in Utah, the case reinforces the importance of anti-retaliation protections under state law. The Labor Commission Appeals Board's finding that Salt Lake County did engage in retaliation suggests that even large governmental employers are subject to meaningful oversight when employees report sexual harassment or other forms of workplace discrimination.
The case also highlights the role of the Utah Labor Commission in adjudicating employment disputes, demonstrating how administrative agencies serve as the first line of resolution for workplace conflicts before cases reach the court system. The multi-level review process, from the Labor Commission through the Court of Appeals to the Supreme Court, illustrates Utah's comprehensive system for ensuring proper resolution of significant employment law disputes.
The timing of the case, with arguments heard in January and the opinion issued in November, reflects the Supreme Court's careful consideration of the complex legal issues presented. As employment law continues to evolve, decisions like *Christensen v. Labor Commission* provide crucial guidance for employers, employees, and administrative agencies navigating the intersection of anti-discrimination law and workers' compensation procedures in Utah.