## Facts

- Three juveniles (Asipeli Mohi, Phillip Lundquist, and Daniel Chaides) were prosecuted for serious felonies listed in Utah’s former juvenile “direct-file” statute, Utah Code § 78-3a-25.
- Prosecutors filed charges directly in district (adult) court rather than initiating proceedings in juvenile court.
- Mohi was alleged to have intentionally or recklessly caused a death with a firearm or facsimile; the State filed an information in district court pursuant to the direct-file provisions.
- Under Utah’s traditional certification process, juvenile court could transfer a juvenile to adult court only after a hearing applying multiple statutory factors and providing procedural protections.
- The direct-file statute permitted prosecutors, without statutory standards, to choose between juvenile court and immediate adult prosecution for qualifying offenses, resulting in different treatment of similarly situated juveniles based solely on prosecutorial choice.

## Issues

1. Whether Utah’s direct-file provisions allowing prosecutors unguided discretion to charge certain juveniles in adult court violate Utah Constitution article I, section 24’s “uniform operation of laws” requirement.

## Decision

- The Utah Supreme Court held the direct-file provisions unconstitutional under article I, section 24.
- The Court concluded the statute created disparate treatment among similarly situated juveniles by allowing prosecutors to select adult prosecution without legislative standards.
- The Court invalidated the direct-file scheme and remanded for further proceedings consistent with its decision.

## Legal Principles

- Utah Constitution article I, section 24 requires laws of general application to operate uniformly on similarly situated persons and constrains classifications that permit unequal treatment.
- A statutory classification must be reasonable: based on real and substantial differences and reasonably related to a legitimate legislative purpose.
- A scheme that permits fundamentally different treatment of members of the same class through unguided enforcement discretion violates uniform-operation requirements because it invites arbitrary and discriminatory application.
- Where juvenile transfer to adult court is authorized, the decision must be governed by articulated, reviewable standards (such as a factor-based judicial certification process), not solely by prosecutorial choice.

## Conclusion

Utah’s direct-file statute was invalid because it allowed prosecutors, without statutory standards, to decide which similarly situated juveniles would be deprived of juvenile-court jurisdiction and protections and prosecuted as adults, contrary to the Utah Constitution’s uniform operation of laws clause.


State v. Mohi, 901 P.2d 991 (Utah 1995)