The Appellate Group

State v. Groce

State v. Groce, 2024 UT App 166 (Harris, J.)

Criminal

Defendant was held without bail pending resolution of a criminal information. Defendant challenged both the district court’s original pretrial status order and the subsequent order. The Utah Court of Appeals affirmed, holding:

  • Defendant’s challenge to the district court’s original pretrial status order was not mooted by the court’s subsequent orders. 
  • The district court did not clearly err in its pretrial detention order and did not abuse its discretion in determining there had been no material change in circumstances. 
  • Practice tip: A party can appeal both the original pretrial status order and subsequent detention orders.  
  • Judicial tip: District courts should ordinarily compare the situation as of the date of the motion with the situation as of the date of the last detention order.

Read the full court opinion