Associate Chief Justice DURRANT, opinion of the Court:
¶ 1 At the age of sixteen, Appellant, Ricky Angilau, was charged as an adult in the district court with several crimes, including murder. Immediately following his arrest, Mr. Angilau was detained in a juvenile detention facility. After three months in the juvenile facility, he was transferred to an adult detention center where he has remained awaiting trial. In this appeal, Mr. Angilau argues that incarcerating him as a child in the adult detention center violated both the Utah Code and the state and federal constitutions.
¶ 2 Following oral argument in this case, but before this opinion was issued, the Utah Legislature amended relevant statutes regarding the pretrial incarceration of children in adult facilities.
¶ 3 As a result of these changes, Mr. Winder contends that all of the issues raised by Mr. Angilau in this appeal are moot. In contrast, Mr. Angilau argues that his claims
¶ 4 First, we hold that all of the issues presented by Mr. Angilau are moot because even if we were to resolve the issues he has raised in his favor, we could not grant the relief he has requested. Second, we decline to address his statutory and unnecessary rigor claims under the public interest exception to the mootness doctrine, because we hold that the statutory claims are unlikely to recur and that the unnecessary rigor claim is inadequately briefed.
¶ 5 At the age of sixteen, Mr. Angilau was charged as an adult with murder, obstruction of justice, carrying a concealed weapon, and possessing a firearm on school premises. Because section 78A-6-701 of the Utah Code (the "Automatic Waiver" statute) provides that "[t]he district court has exclusive original jurisdiction over all persons 16 years of age or older charged with ... an offense which would be murder or aggravated murder if committed by an adult,"
¶ 6 Immediately after his arrest, Mr. Angilau was briefly held in a juvenile detention center. From there he was transferred to the Adult Detention Center (the "ADC"), a jail for adults operated by the Salt Lake County Sheriff.
¶ 7 Upon arriving at the ADC, Mr. Angilau was housed with the general population. During his time in the general population, he had several adult cellmates and spent eight hours per day with approximately sixty other adult inmates, some of whom were in jail on aggravated felony charges. While Mr. Angilau was in the general population, there was not constant visual monitoring in the cells or common areas of the ADC. Additionally, although the cells did have intercoms, there was only periodic guard supervision.
¶ 8 After approximately three months in the ADC's general population, Mr. Angilau was transferred to the maximum security unit where he spent, on average, twenty-three hours per day in a cell with his cellmate. Like in the general population, inmates detained in the maximum security unit of the ADC are not under constant video surveillance.
¶ 9 In March 2009, Mr. Angilau filed a Petition for Extraordinary Relief and Request for Immediate Temporary Relief in which he claimed that his incarceration in an adult jail was illegal and demanded his immediate release. The Third District Court denied Mr. Angilau's petition based on its interpretation of relevant laws in the juvenile justice statutory scheme.
¶ 10 Mr. Angilau appealed the denial on statutory and constitutional grounds, and we accepted the appeal. On appeal, he contends that his incarceration in an adult facility violated the Utah Code and the state and federal constitutions. Specifically, in his initial briefing, Mr. Angilau first argued that his incarceration violated the Utah Code because the code did not expressly authorize the detention of children charged under the Automatic Waiver statute in adult facilities. He also argued that his incarceration violated the code because the ADC did not comply with the safety standards adopted by the Board of Juvenile Justice Services (the "Board"), as was required by statute. Additionally, Mr. Angilau argued that the Automatic Waiver statute violated the Due Process and Equal Protection Clauses of the United States Constitution, and the uniform operation of laws clause of the Utah Constitution. These issues are addressed in our opinion in a companion case issued prior to this opinion.
¶ 11 After oral argument, but before this opinion was issued, the Utah Legislature significantly revised the statutory scheme governing the incarceration of children in adult facilities.
¶ 12 Following the 2010 amendment, section 62A-7-201 now provides that "[c]hildren under 18 years of age ... may not be confined in jails, lockups, or cells used for persons 18 years of age or older who are charged with crime ... except as provided in... specific statute or, in conformance with standards approved by the [B]oard."
¶ 13 On November 27, 2010, Mr. Angilau turned eighteen years of age. Mr. Winder contends that the statutory amendments and Mr. Angilau's new status as an adult have mooted all of the issues raised in this appeal. In contrast, Mr. Angilau contends that his claims are not moot. Additionally, he argues that even if the issues he has raised are moot, we should still address them under the public interest exception to the mootness doctrine. We have jurisdiction to hear this appeal under section 78A-3-102(3)(i) of the Utah Code.
¶ 14 The determination of whether we will reach the merits of a mooted issue in any particular case rests within the discretion of this court.
¶ 15 The issues presented by Mr. Angilau in this appeal are moot. "`An appeal is moot if during the pendency of the appeal circumstances change so that the controversy is eliminated, thereby rendering the relief requested impossible or of no legal effect.'"
¶ 16 In the instant case, Mr. Angilau contends that his incarceration as a child in the ADC violated the Utah Code and the state and federal constitutions. All of the arguments advanced by Mr. Angilau in support of these claims rest entirely on his former status as a child. And significantly, the only relief Mr. Angilau has sought in this case is that we order his immediate release from the ADC.
¶ 17 Because Mr. Angilau is now eighteen years of age, even if we were to resolve the issues he has raised in his favor, we could not grant the relief he has requested. This is so because, as even Mr. Angilau concedes, the
¶ 18 Mr. Angilau's arguments to the contrary are not persuasive. Specifically, Mr. Angilau contends that his claims are not moot because, in his view, "a decision ... recognizing the unlawfulness of his incarceration might still affect his rights, as he may be entitled to restitution as a victim of the Sheriff's and District Attorney's crimes against him."
¶ 19 In sum, because a finding by this court that the incarceration of children charged under the Automatic Waiver statute in an adult facility violated either the preamendment version of the code or the state or federal constitutions would have no effect on Mr. Angilau's rights, as he is now an adult, we hold that the issues presented by Mr. Angilau are moot.
¶ 20 In some circumstances, we will "exercise our discretion and address a moot issue if we find that it `falls within the public interest exception to the mootness doctrine.'"
¶ 21 To address an issue under the public interest exception to the mootness
¶ 22 Mr. Angilau argues that his incarceration in an adult jail violated the Utah Code in two principal ways. First, he contends that his transfer to and incarceration in the adult jail violated the code because the code did not expressly authorize children charged under the Automatic Waiver statute to be incarcerated in adult facilities. Second, he contends that his incarceration violated the code because the ADC did not comply with the safety standards adopted by the Board, including a requirement that juveniles be under constant video surveillance.
¶ 23 Following oral argument in this case, but before the issuance of this opinion, the Utah Legislature amended the sections of the Utah Code regulating the pretrial incarceration of juvenile offenders in adult facilities.
¶ 24 Because these statutory amendments expressly authorize the conditions that Mr. Angilau contends violated the preamendment version of the code, and thereby render these conditions nonviolations under the amended statute, the violations alleged by Mr. Angilau are not likely to recur.
¶ 25 The final issue we must resolve is whether to address Mr. Angilau's claim that his incarceration as a child in the ADC violated the unnecessary rigor clause of the Utah Constitution under the public interest exception to the mootness doctrine. Application of the public interest exception is an issue within the sound discretion of this court.
¶ 26 We readily acknowledge that the incarceration of children in adult facilities without the safety measures mandated by the Board may be an issue of public concern. We also recognize that because the amended version of the code authorizes such conditions, the incarceration of children in adult facilities failing to implement these measures is likely to recur. And because of the short time that juveniles may have to challenge their incarceration in adult facilities before becoming adults, we also acknowledge that this issue may be capable of evading review. But even though the question of whether Mr.
¶ 27 We have previously explained that our adequate briefing standard "require[s] `not just bald citation to authority but development of that authority and reasoned analysis based on that authority.'"
¶ 28 Mr. Angilau's briefing of the unnecessary rigor issue has failed to satisfy our adequate briefing requirements. Indeed, instead of presenting and developing our existing unnecessary rigor case law, Mr. Angilau has spent most of the two pages of his unnecessary rigor claim simply setting forth selected facts from his case. Moreover, rather than applying our unnecessary rigor case law to these facts and offering reasoned analysis as to why these conditions might be unnecessarily rigorous, Mr. Angilau's brief simply proceeds by making conclusory statements and demanding that we find that the conditions of his incarceration were unnecessarily rigorous.
¶ 29 Furthermore, even if we were to conclude that Mr. Angilau had adequately briefed his unnecessary rigor claim based on the specific conditions of his incarceration, we would still decline to apply the public interest exception and address the broader question raised by Mr. Angilau as to whether the pretrial confinement of all juveniles in all adult facilities in the state of Utah that do not comply with the standards adopted by the Board always violates the unnecessary rigor clause of the Utah Constitution. This is because we feel that the briefing and record before us are simply inadequate to make such a categorical determination, particularly because our unnecessary rigor analysis requires a fact-intensive inquiry.
¶ 30 For these reasons, we decline to address Mr. Angilau's unnecessary rigor claim under the public interest exception to the mootness doctrine. We therefore leave the issue to be addressed and resolved in a more appropriate case.
¶ 31 As a result of Mr. Angilau's status as an adult, we hold that the issues he raises on this appeal are moot. We also decline to address his statutory and unnecessary rigor claims under the public interest exception to the mootness doctrine, because we hold that the statutory claims are unlikely to recur and that the unnecessary rigor claim is inadequately briefed. We therefore deny Mr. Angilau's Petition for Extraordinary Relief.
¶ 32 Chief Justice DURHAM, Justice PARRISH, Justice NEHRING, and Judge HADLEY concur in Associate Chief Justice DURRANT'S opinion.
¶ 33 Due to his retirement, Justice WILKINS does not participate herein; District Judge SCOTT M. HADLEY sat.
¶ 34 Justice THOMAS R. LEE became a member of the Court on July 19, 2010, after oral argument in this matter, and accordingly did not participate.