Utah Supreme Court
State v. Randolph
August 4, 2022515 P.3d 444
Summary
The Utah Supreme Court affirmed the district court’s denial of pre‑trial detention, holding that the substantial‑evidence determination is a law‑like mixed question reviewed de novo, while the clear‑and‑convincing findings of danger, flight risk, and lack of release conditions are fact‑like mixed questions reviewed for clear error. The Court also reaffirmed the traditional meaning of “substantial evidence” under the Utah Constitution and Bail Statute.
Holding
- Whether the appellate standard of review for a district court’s determination that substantial evidence exists to support the charge is de novo or deferential.. The determination is a law‑like mixed question of law and fact and is reviewed de novo.
- Whether the appellate standard of review for a district court’s finding of clear and convincing evidence that the defendant is a substantial danger or likely to flee is deferential or de novo.. The finding is a fact‑like mixed question and is reviewed for clear error (deferential).
- Whether the appellate standard of review for a district court’s factual finding that no conditions of release would ensure public safety or the defendant’s appearance is clear error or de novo.. The finding is a pure factual determination reviewed for clear error.
- What the proper meaning of “substantial evidence” is under Utah Constitution article I, section 8 and Utah Code § 77‑20‑1.. “Substantial evidence” retains the meaning of the former “proof evident or presumption strong” standard and requires evidence that would support a reasonable jury verdict.
Docket Case No. 20200881