Jason Donald simpson/joe Paul Martinez v. Hons. miller/steinle/state

Summary

The court held that Arizona's categorical denial of bail for defendants charged with sexual conduct with a minor under fifteen violates the Fourteenth Amendment because the offense does not inherently establish future dangerousness and the procedure does not require an individualized dangerousness determination. The court held that defendants may instead be detained under a separate procedure requiring clear and convincing proof of substantial danger and the inadequacy of release conditions. The trial court's decision was reversed, the court of appeals' opinion was vacated, and the matter was remanded.