The Appellate Group

Randolph v. State

Randolph v. State, 2022 UT 34 (Pearce, J)

Criminal Law

The State charged Defendant and filed a motion for pretrial detention under Utah Code 77-20-1. The district court concluded that the State presented substantial evidence to support the charges and clear and convincing evidence that Defendant was a danger to the community and detained Defendant. Defendant appealed. The Utah Supreme Court affirmed, holding:

  • The district court did not err in making its bail determination. In the bail context, “substantial evidence” means facts adduced by the State, notwithstanding contradiction by the defense, that would furnish the jury with a reasonable basis for a guilty verdict—if believed by the jury. In the bail context, the district court has the discretion to weigh conflicting pieces of evidence and ultimately decide that, in light of the conflict, there is not a basis on which a reasonable jury could reach a guilty verdict.

Read the full court opinion