State v. Mohi

In State v. Mohi, 901 P.2d 991 (Utah 1995), the Court stated that: "for a law to be constitutional under the uniform operation of laws provision, it is not enough that it be uniform on its face. What is critical is that the operation of the law be uniform. A law does not operate uniformly if 'persons similarly situated' are not 'treated similarly.'" At that time, the Court articulated a two-step assessment for determining whether a statute comports with the uniform operation of laws provision of the Utah Constitution. "'First, a law must apply equally to all persons within a class. Second, the statutory classifications and the different treatment given the classes must be based on differences that have a reasonable tendency to further the objectives of the statute.'" Id. at 997. This requires that the Court "first determine what classifications . . . are created by the statute. Second, we must determine whether different classes . . . are treated disparately. Finally, if any disparate treatment exists between classes . . . we must determine whether the legislature had any reasonable objective that warrants the disparity." Mohi, 901 P.2d at 997.