Angilau v. Winder
2011 UT 13
Utah2011Background
- At age sixteen, Angilau was charged as an adult under the Automatic Waiver statute for murder and related offenses.
- He was detained first in a juvenile facility, then transferred to an adult detention center (ADC) for pretrial detention.
- In the ADC he shared with adults, faced minimal constant supervision, and spent eight hours daily among about sixty inmates.
- After about three months in general population, he was moved to the maximum security unit, with lengthy solitary-like confinement.
- In March 2009 he filed an extraordinary relief petition; after denial, he appealed raising statutory, constitutional, and Board-safety-standards arguments.
- Before the opinion, Utah amended relevant statutes; Angilau turned eighteen on November 27, 2010; the parties dispute mootness and public-interest relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Angilau's claims moot after turning eighteen and statutory amendments? | Angilau | Winder | Yes; claims moot; relief cannot be granted. |
| Does the public interest exception permit addressing the statutory claims? | Angilau | Winder | Not under statutory claims; not likely to recur. |
| Does the public interest exception allow addressing the unnecessary rigor claim? | Angilau | Winder | Not addressed due to inadequate briefing. |
Key Cases Cited
- State v. Angilau, 245 P.3d 745 (Utah Supreme Court, 2011) (companion mootness/constitutional analysis)
- McBride v. Utah State Bar, 242 P.3d 769 (Utah Supreme Court, 2010) (public interest mootness discretion)
- Ellis v. Swensen, 16 P.3d 1233 (Utah Supreme Court, 2000) (mootness policy discretion)
- Frito-Lay v. Utah Labor Comm'n, 222 P.3d 55 (Utah Supreme Court, 2009) (mootness framework and standards)
- Dexter v. Bosko, 184 P.3d 592 (Utah Supreme Court, 2008) (fact-intensive analysis for unnecessary rigor)