State v. Angilau
2011 UT 3
| Utah | 2011Background
- Sixteen-year-old Angilau was charged in district court with murder and related offenses under Utah's automatic waiver statute.
- The district court held the automatic waiver statute constitutional and transferred the case to the district court's jurisdiction without juvenile hearing.
- Angilau sought interlocutory appeal arguing the statute is unconstitutional on multiple grounds, which the parties later stipulated were mooted by 2010 legislative amendments.
- The case proceeded while statutory amendments were in effect; the court reviews the statute's constitutionality as applied to Angilau.
- Utah Supreme Court applies rational-basis review to the statutory classifications created by age and offense, and upholds the statute as constitutional when applied to Angilau.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the automatic waiver statute violate substantive due process? | Angilau contends the statute implicates fundamental rights requiring heightened scrutiny. | State argues rational-basis review governs; statute serves legitimate public-safety objectives. | No due-process violation; statute passes rational-basis review. |
| Does the automatic waiver statute violate procedural due process? | Angilau asserts he should have had juvenile-court procedural protections before transfer. | ||
| State maintains no initial juvenile-court right existed for Angilau under the statute. | No procedural-due-process violation; no right to a juvenile-hearing before charging under automatic waiver. | ||
| Does the statute violate Utah's uniform operation of laws or the federal Equal Protection Clause? | Angilau asserts disparate treatment based on age and offense with unconstitutional classifications. | State contends classifications are rational and serve legitimate aims. | Statute withstands uniform-operation/equal-protection scrutiny; classifications rationally related to legitimate objectives. |
| Does the statute violate Utah's prohibition on the enactment of special or private laws? | Angilau claims the statute creates unlawful special classifications for juveniles. | State asserts no invalid special-law issue given rational-basis analysis. | No violation; analysis same as uniform-operation rationale. |
| Is there a constitutional right for all minors to be prosecuted in juvenile court? | Angilau argues a statutory/constitutional right to juvenile-court treatment exists. | State denies such a broad right and relies on Mohi and related authorities. | No recognized right for all minors to juvenile court; legislature may exclude oldest minors from juvenile jurisdiction. |
Key Cases Cited
- Merrill v. Utah Labor Comm'n, 223 P.3d 1089 (Utah 2009) (statutory constitutionality reviewed with presumption of validity; rational basis approach)
- State v. Herrera, 993 P.2d 854 (Utah 1999) (prescribes approach to testing constitutionality of legislation)
- State v. Mohi, 901 P.2d 991 (Utah 1995) (juvenile rights and transfer considerations; no right to juvenile status for all juveniles)
- Kent v. United States, 383 U.S. 541 (1966) (due process requires opportunity for hearing before waiver of juvenile jurisdiction)
- Kelley v. Kaiser, 992 F.2d 1509 (10th Cir. 1993) (cases addressing initial assumption of juvenile jurisdiction and transfer)
- Blue Cross & Blue Shield of Utah v. State, 779 P.2d 634 (Utah 1989) (uniform operation of laws framework and classification scrutiny)
- Schofield v. State, 63 P.3d 667 (Utah 2002) (analysis framework for classifications under uniform operation of laws)
- Drej v. State, 233 P.3d 476 (Utah 2010) (three-part rational-basis test for classifications and legitimate objectives)