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Bell v. Superior Court
Arizona Court of Appeals
117 Ariz. 551, 574 P.2d 39 (1977)
Dennis Bell (defendant), a juvenile, was arrested by police officers and formally charged with the crime of receiving stolen property. The next day, Bell was given a detention hearing. Bell requested reasonable bail and a probable-cause hearing, i.e., a hearing at which the state would be required to provide evidence showing there was probable cause to believe that Bell had actually committed a crime. The juvenile court denied the bail request, finding that Bell might flee or be a danger to himself or others if he were released pending trial. The juvenile court also denied Bell’s request for a probable-cause hearing. Then, without any evidentiary basis for believing that Bell had actually committed a crime, the juvenile court ordered that Bell would be incarcerated until his trial. Bell appealed these rulings. Bell’s pretrial detention ended before the appeal hearing, making his claim moot. However, because the issue of pretrial detention was likely to come up in other cases, the appellate court agreed to review the issue to provide guidance for future situations.
Rule of Law
Holding and Reasoning (Richmond, J.)
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