SALT LAKE CITY — The Utah Court of Appeals on Aug. 14, 2025, affirmed a judgment requiring Salt Lake City Corporation to pay R.O.A. General Inc. $325,000 as just compensation for a billboard it had sought to relocate after the city denied the request. Judge John D. Luthy, writing for the panel, concluded the city was estopped from denying compensation on the ground that the billboard had been demolished before the relocation request was filed.

The case matters because it interprets how Utah’s municipal-relocation scheme for billboards works and confirms that a municipality that invites a property owner to pursue a statutory relocation request may be barred from later denying compensation on narrow grounds. “The City is estopped from denying compensation to CBS on the basis that it demolished its billboard prior to submitting its Section 511 request,” Judge Luthy wrote, using the court’s earlier reference to the owner as CBS.1

R.O.A. General (then operating as Outfront Media, previously CBS) owned a freeway-facing billboard on land it leased from Corner Property LC. After demolition of the sign in 2014 following the lease dispute, R.O.A. sought relocation under Utah Code § 10-9a-511(3)(c) (2014) — commonly called a Section 511 request — which can trigger payment of just compensation under Utah Code § 10-9a-513(2)(a)(iv) (2014) if a municipality refuses to permit relocation under defined spacing and zone conditions.

Salt Lake City first denied an application filed under Utah Code § 72-7-510.5 (a Title 72 application) on Dec. 4, 2014, noting that the sign had been demolished but inviting the owner to “modify its application to either (a) bank the billboard credits for the now demolished [s]ign . . . or (b) request to relocate the [s]ign under Utah Code [section] 10-9a-511(3)(c)(i),” the opinion recounts quoting the city’s letter. The city later denied a Section 511 relocation by the owner while approving a competing request from Corner Property to move a different billboard to the parcel in question.

The owner challenged the denials in administrative and district-court proceedings, and the Utah Supreme Court in Outfront Media, LLC v. Salt Lake City Corp., 2017 UT 74, 416 P.3d 389, held that section 10-9a-513(2)(a) does not mandate relocation but specifies when just compensation must be paid if a municipality denies relocation. After further district-court rulings, a stipulated valuation of the demolished billboard at $325,000, and an earlier appellate remand, the district court on remand granted summary judgment for R.O.A. General, concluding that under the undisputed facts the owner met the statutory requirements for compensation and that the city’s December 2014 communications and subsequent representations estopped it from relying on a new argument — that demolition before filing the Section 511 request precluded compensation.

Salt Lake City renewed two statutory arguments on remand: (1) that the relocation statute’s spacing provisions should be read to deny compensation when multiple applicants seek essentially the same location, and (2) that compensation requires an “existing” billboard capable of being relocated when the owner submits a Section 511 request. The Court of Appeals rejected the city’s spacing argument, concluding the statutory phrase required an actually “existing” sign within the specified distance (for interstate-facing billboards, 500 feet) and declined to rewrite unambiguous statutory text under the narrow “absurdity” doctrine. The court then applied equitable estoppel, finding the city’s written invitations and later statements sufficiently clear for the owner to reasonably rely on them to its detriment.

The appeals panel affirmed the district court’s summary judgment ordering Salt Lake City to pay $325,000. The opinion cites Salt Lake City Code § 21A.46.160 (billboard banking and permitting rules), Utah Code § 72-7-510.5 (2014) (Title 72 obstruction remedy), Utah Code §10-9a-511(3)(c) (2014) (municipal waiver/relocation request), and Utah Code §10-9a-513(2)(a)(iv) (2014) (compensation trigger), and relies on the procedural history including Outfront Media, LLC v. Salt Lake City Corp., 2017 UT 74, and the court’s own earlier remand opinion, R.O.A. Gen. Inc. v. Salt Lake City Corp., 2022 UT App 141.

The decision leaves intact a pathway for billboard owners who pursue statutory relocation claims after municipal denials, and it underscores limits on a municipality’s ability to assert new statutory defenses after inviting an owner to pursue a remedy. The court did not order any additional damages or fees beyond the stipulated $325,000 award. — By the Court of Appeals panel, Judge John D. Luthy, Judges Ryan M. Harris and Amy J. Oliver concurred.