In re White

Summary

The court held that review of a trial court’s denial of bail under article I, section 12(b) requires substantial-evidence review of the factual findings supporting a qualifying offense and the likelihood of future great bodily harm, followed by abuse-of-discretion review of the ultimate detention decision. Applying those standards, the court concluded that the record supported findings that White aided and abetted qualifying violent and sexual offenses and that his release posed a substantial likelihood of great bodily harm. The court affirmed the Court of Appeal despite recognizing that White’s claim had become moot after he pleaded guilty, because the issue was important, likely to recur, and capable of evading review.