State v. MLC

MLC (defendant), a 16-year-old, was charged with armed robbery in juvenile court. The juvenile-court proceeding was a civil proceeding that was initiated with a petition of criminal information. By statute, the armed-robbery charge made MLC a serious youth offender and required the juvenile court to consider whether to transfer him to adult criminal court at a determination hearing. MLC asked the juvenile court to set bail so that he could be free while awaiting the determination hearing. The juvenile court denied MLC’s request for bail, and MLC was detained until the determination hearing. At the hearing, the juvenile court determined that MLC should be transferred to criminal court and tried as an adult. The juvenile court then set MLC’s bail. MLC appealed the juvenile court’s earlier ruling denying him bail while he waited for the determination hearing. MLC argued that denying him bail while he was in the juvenile court’s custody violated his Eighth Amendment and Equal Protection rights under the United States Constitution, as well as his rights under Utah’s state constitution. By the time MLC’s appeal was ready to be heard, his criminal-court bail had been set, making his personal claim moot. However, because the issue of bail was likely to come up in other cases, the Utah Supreme Court agreed to review the issue to provide guidance for future situations.