STATUTE NOTE

Deserted in Deseret: How Utah's Emancipation Statute is Saving Polygamist Runaways and Queer Homeless Youths T. Christopher. Wharton* I. INTRODUCTION

In the snow-covered streets of Salt Lake City, among busy holiday shoppers and twinkling Christmas lights, an eighteen-year-old bisexual youth known as "Paine" prepared for his sixth winter without a home.' His depraved circumstances left him selling furniture and drugs to support himself' Fearing rejection by their families and life within Utah's juvenile system, Paine and a number of other gay, lesbian, bisexual, and transgender (GLBT or queer) youths pay a heavy price for the freedom to be themselves.3 Meanwhile, between red rock canyons and miles of desert, a teenage runaway named Franky arrived in St. George after leaving a polygamist community on the Utah-Arizona border. 4 After being excommunicated by Warren Jeffs, prophet and former leader of the Fundamentalist Church of Jesus Christ of Latter Day Saints (FLDS), he was banned from communicating with the three mothers and nearly three dozen siblings he left behind. 5 Like many polygamist family runaways (or the so-called "Lost Boys"), shock and desperation eventually led Franky into a downward spiral of drinking, drug use, and trouble with the law.' Paine and Franky each represent very different subsets of the greater population of runaway and homeless youths in the state of Utah: queer homeless youths that gravitate toward urban centers in the north, and polygamist family runaways scattering throughout the south. However, the sacrifices and struggles shared by these two divergent groups present an ironic connection that, until recently, the law has failed to remedy. This Note begins with an explanation of the political and legal history of emancipation law in Utah as it relates to the State's runaway and homeless youth population. It will then focus on the two subgroups most likely to benefit from Junior Staff Member, Journal of Law & Family Studies; J.D. candidate 2009. l Alexandra Woodruff, The Invisible Kids, SALT LAKE M ETRO, Dec. 9, 2004, at 12. 2 Id. 3 Id. 4 Dan Simon & Amanda Townsend, Warren Jeffs' "Lost Boys" Find Themselves in Strange World, CNN, Sept. 7, 2007, http://www.cnn.com/2007/US/09/07/lost.boystindex.html. 5 Id. at "Timeline" hyperlink. 6 Estimates on the number of Lost Boys in Utah range greatly, from approximately 400 to 750 cases. Compare Simon & Townsend, supra note 4, with Press Release, Utah Attorney General's Office, The Lost Boys Law: Governor Signs Emancipation Bill to Help Homeless Teens (May 2, 2006) [hereinafter: Lost Boys Press Release], available at http://attorneygeneral.utah.gov/PrRel/prma y22006.htm.

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emancipation resources: GLBT youths and polygamist family runaways. It will conclude with the legislative history leading up to the adoption of the Emancipation of a Minor Act, an outline of some of its key provisions (such as allowing emancipated minors to enter into contracts and provide consent to legal activities) in comparison to other state statutes, and several suggestions for possible improvements to the bill. II. BACKGROUND

In 2006, Utah became the thirtieth state to enact an emancipation law allowing minors with disadvantaged and often heartbreaking childhoods to seek legal autonomy.' Although emancipation provisions for extraordinary cases existed somewhere in the shadows of Utah common law, there were no guidelines . in place to enable courts to help free some of the State's population of runaway and homeless youths from a life on the streets. 8 Since becoming law on May 1, 2006, the Emancipation of a Minor Act has provided juvenile courts with the guidelines needed to standardize the emancipation process. However, the problems associated with runaway children and youth homelessness are far from new. A generation ago, when Utah State Representative Rosalind "Roz" McGee was just beginning her tenure as Executive Director of Voices for Utah Children, a number of insufficiencies in Utah's child welfare system were already apparent. 1 ° These insufficiencies enabled a number of issues, including youth homelessness, to intensify. See, e.g., ALA. CODE §§ 26-13-1 through 7 (2007); ALASKA S TAT. § 9-55-590 (2006); C AL. FAM. CODE § 7000-7002 (West 2007); C OLO. REV. S TAT. § 19-1-103 (2006); C ONN. G EN. S TAT. § 46B-815t (2006); F LA. STAT. § 743.0 (2006); H AW. REV. STAT. § 577-25 (2006); I LL. C OMP. S TAT. 750/30-1 (2006); I ND. CODE § 31-34-20-6 (2007); KAN. S TAT. ANN. § 38-108 (2006); L A. C IV. CODE ANN. art. 3992 (2006); M E. REV. S TAT. ANN. tit. 15, § 7 (2006); M D. CODE ANN. FAM. L AW § 3-826.1 (LexisNexis 2007); M ASS. GEN. LAWS ch. 201, § 5 (2007); M ICH. C OMP. L AWS § 722.4 (2007); M ONT. CODE ANN. § 41-3-4 (2006); N EV. REV. S TAT. § 129.80-140 (2006); N.H. R EV. S TAT ANN. § 21-B:2 (LexisNexis 2007); N.M. S TAT. § 32A-21-4 (2006); N.C. G EN. STAT. § 7B-3101-07 (2006); O KLA. STAT. tit. 10, § 90-94 (2006); O R. REV. S TAT. § 419B.552 (2006); R.I. G EN. L AWS § 14-1-15.1 (2006); S.D. C ODIFIED L AWS §§ 25-5-19 through 25 (2006); T EX. C ODE ANN. tit 2, § 31.001 (2006); VT. S TAT. ANN. tit. 12, § 7151 (2006); W ASH. REV. C ODE § 13.64.050 (2006); W. V A. C ODE § 49-7-27 (2006); W YO. S TAT ANN. § 14-1-101 (2006). Pennsylvania does not have a state-wide emancipation statute; however, emancipation laws exist, in various forms, in the following counties: Blair, Bradford, Cambria, Carbon, Centre, Clarion, Clinton, Columbia, Crawford, Cumberland, Dauphin, Elk, Erie, Forest, Franklin, Fulton, Greene, Juniata, Lackawana, Lancaster, Luzerne, Lycoming, Mercer, Mifflin, Monroe, Montour, Northampton, Northumberland, Philadelphia, Pike, Potter, Tioga, Warren, Washington, and York. J UVENILE LAW CENTER, E MANCIPATION IN THE UNITED STATES, http://www.jlc.org/factsheets/4/ (last visited Apr. 7, 2008). 8 See State in Interest of R.R. v. C.R., 797 P.2d 459, 464 (Utah Ct. App. 1990) ("[T]he common law doctrine of emancipation is, by virtue of [UTAH C ODE ANN. § 68-3-1 (1990)], a part of the law of this jurisdiction constituting the rule of decision in Utah courts, unless it conflicts with the statutes or constitutions of the United States or of Utah."). 9 Emancipation of a Minor, H.R. 30, 2006 Gen. Sess. (Utah 2006), available at http://www.le. state.ut.us/-2006/htindoc/hbillhtm/HB0030.htm (last visited Sept. 14, 2007). 10 Telephone Interview with Rep. Rosalind "Roz" McGee, Utah House of Reps., former Exec. Dir. of Voices for Utah Children (Aug. 31, 2007).

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In 1993, these issues culminated in a class-action lawsuit filed by the National Center for Youth Law, on behalf of a number of neglected children, against the state of Utah. 1 ' The case of David C. v. Leavitt finally ended with a settlement agreement in May of 2007, after the State promised specific and substantial improvements in ninety-five areas of its child welfare system. 12 Although David C. did not directly address the problem of youth homelessness, it drew attention and support to youth issues in the law and perhaps allowed a potentially controversial bill to pass successfully through the Utah State Legislature in 2006. III. UTAH'S RUNAWAY AND HOMELESS YOUTH POPULATIONS

Although no one can point to any exact figures, the number of runaway and homeless youths—callously referred to as "throwaway youths"—has been on the rise in recent years, and an amassing cloud of dangers continue to follow them." As Teresa Stocks, Program Manager of the Homeless Youth Resource Center (HYRC) explained, many of the youths the Center encounters were born into a life of indigence, homelessness, welfare, or extreme abuse and neglect. 14 These types of youths often lack the socialization skills necessary to survive in everyday society, not to mention the resources necessary to make a case for their own emancipation before a judge. 15 Additionally, in many of those same cases, the minor's parents have already lost custody to the State, their whereabouts are unknown, or the parents themselves are homeless.16 The Emancipation of a Minor Act sponsored by Rep. McGee was not officially created for any specific group, but the potential benefits for homeless and runaway youths—such as the ability to contract, receive medical attention, and secure legal autonomy—could provide them with the legal capacity to get themselves off the streets." However, shortly after its inception, the bill gained particular attention for the benefits it offered to Lost Boys and GLBT minors who have been rejected by their families.18 The first group most likely to benefit from the new emancipation law is the GLBT homeless youth. According to a point-in-time survey compiled by HYRC in 2007, approximately thirty-four percent of the youths surveyed (ranging from age fifteen to age twenty-three) identified themselves as gay, lesbian, or bisexual.19 When asked why they became homeless, approximately seven percent of the total 11 David C. v. Leavitt, 242 F.3d 1206, 1207 (10th Cir. 2001). 12 /d. at 1208. 13 E.g., Rob Orton, Bill May Help Utah's Homeless Youth, S ALT L AKE METRO, Dec. 9, 2004, at 13; Jacob Santini, Bill May Aid 'Throwaway Kids, ' SALT LAKE TRm., Nov. 15, 2004, available at http://www.cyc-net.org/today2004/today041116.html. 14 Interview with Teresa Stocks, Program Manager, Homeless Youth Res. Ctr. (Aug. 31, 2006). 15 Id. 16 id. 17 McGee, supra. note 10. 18 Santini, supra note 13. 19 H OMELESS Y OUTH RES. C TR. OF UTAH, HYRC DEMOGRAPHIC SURVEY (2007) [hereinafter "HYRC S URVEY").

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individuals in the survey reported that they were "forced to leave their parents' home because they were gay."2° Queer homeless youths are more likely to seek out the benefits from the bill because, unlike the general homeless youth population, "GLBT youths have typically lived a much more 'normal' childhood up until the time they ran away or were forced to leave" due to family rejection. 21 As a result of such an upbringing, queer youths tend to be better educated and more socially literate; they tend to have at least some resources to rely upon (such as friends or other family members); they tend to have a cursory knowledge of their individual rights; and they know how to seek help.22 The second group most likely to benefit from the new emancipation law are the Lost Boys (and girls) of southern Utah. 23 The State estimates that the number of runaways may include as many as 750 youths coming from multiple polygamist communities around the twin cities of Hildale, Utah, and Colorado City, Arizona, where the FLDS headquarters are located. 24 "Some were kicked out [of their families] when they started watching R-rated movies, hanging out with girls, smoking cigarettes, or using drugs; others left because they wanted to do those things."25 The Lost Boys are among the majority of runaways who have abandoned some or all of their beliefs in the FLDS church, rejecting the practice of plural marriage and a number of other strict religious doctrines. However, there are others who "claim they are being driven away to lessen the competition for plural wives." 26 Polygamist family runaways are more likely to benefit from the new bill because—in addition to legally empowering estranged children—supporting the emancipation of polygamist children contributes to the State's interest in prosecuting and dismantling the practice of polygamy. IV. THE LIVES OF RUNAWAY AND HOMELESS YOUTHS

After leaving home, many runaways and homeless youths express a cathartic sense of freedom from the abuse and repression they previously suffered. According to a homeless youth questionnaire compiled in 2006, thirty-seven percent of the respondents had been sexually assaulted and sixty-five percent had been sexually abused. 27 The survey also revealed that eighty-five percent of the respondents had been physically abused and as many as ninety-six percent had suffered from emotional abuse. 28 However, despite their newfound freedom, 20 Id. 21 Id. 22 Stocks, supra note 14. 23 Santini, supra note 13. 24 Id. 25 Brooke Adams, State Tries to Help Lost Boys Head in Right Direction, Feb. 19, 2006. 26 Id. 27 Lost Boys Press Release, supra note 6. 28 Id

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homeless youths and runaways are still bound and gagged by a lack of resources and by their minority status under the law. For many homeless youths and runaways, welfare programs such as shelters and foster homes provide little or no relief. For example, queer youths often feel a profound sense of rejection which prevents them from seeking help from the state.29 In cases where they are placed in foster care, some continue to experience abuse or a lack of acceptance from their foster families." As for polygamist family runaways, most have been raised with a strong distrust of government agencies and services because of the reclusive practices of polygamist communities.3/ Additionally, homeless youths and runaways tend to avoid adult shelters altogether because of the common risk of being sexually assaulted or raped by adult predators.32 When it comes to surviving on their own, GLBT homeless youths are "very clever and very resourceful," but absent any government welfare, their resources are limited to volunteer organizations. 33 In Salt Lake City, "drop-in" centers like HYRC can help provide for basic needs like food and shelter during the day, but they lack the ability to provide youth-specific shelters and transition programs. Utah's shelter laws—Which require parental consent or Division of Child and Family Services notification in order to legally harbor a minor—can frustrate the situation as wel1.34 Fearing for their safety and with nowhere else to go, many queer homeless youths are forced to find shelter on the streets and in abandoned buildings.35 Polygamist runaways have access to resources that other homeless youths do not, such as groups of former Lost Boys "clump[ed] together in southern Utah and Wasatch Front cities."36 In St. George, Lost Boys can also seek help from the Diversity Foundation, a nonprofit organization created specifically for FLDS runaways. However, Dan Fisher, creator of the foundation and a former FLDS member, acknowledged the serious lack of resources available for most runaways. 37 The minority status of many homeless youths also prevents them from being able to consent to regular physical and mental health treatment. 38 In addition to HYRC, many depend on the Open Door Clinic operated out of the Salt Lake Valley Health Department, where treatment for substance abuse and dangerous sexual practices is common among homeless youths. 39 As the experiences of Paine and Franky illustrate, homeless youths face a higher potential for experiencing 29 Stocks, supra note 154. 3 ° Id. 31 Id. 32 Id. 33

34 UTAH CODE ANN. § 62A-4a-501 (2006). 35 Stocks, supra note 154. 36 Adams, supra note 25. 37 Id. 38 Stocks, supra note 154. 39 Id.

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drug and alcohol use and addiction. 4° According to HYRC's 2007 survey, fifty-one percent of homeless youths reported using drugs regularly and seventeen percent consider themselves addicted to drugs or alcohol. 41 The HYRC survey suggests these dangers are not uncommon, considering that twenty-four percent of homeless youths reported trading sex for food, drugs, or a place to stay. 42 Sexual promiscuity presents an additional threat, especially since sixty-six percent of homeless youths reported being sexually active, but only thirty-eight percent reported using condoms regularly.43 To make matters worse, such instability and difficult physical realities give rise to serious mental health problems as well. Too often, conditions such as these can result in permanent, life-altering consequences such as sexually transmitted infections, severe depression, mental illness, chemical dependency, and even suicide. 44 This is also reflected by the HYRC survey, where thirty-four percent of homeless youths reported attempting suicide, most of whom reported attempting suicide more than three times.45 While HYRC and the Open Door Clinic can provide initial care for substance abuse and sexual health hazards, they lack the resources necessary to sustain ongoing, comprehensive substance abuse rehabilitation and safe-sex programs. V. THE LEGISLATIVE HISTORY OF UTAH'S EMANCIPATION LAW

The legislative history of the Emancipation of a Minor Act begins with the original draft written on Melissa Larsen's dinning room table. 46 Larsen, a certified social worker, became intimately familiar with the problems facing homeless youths while leading the Utah Pride Center's homeless queer youth program and while working as a therapist for abused and neglected teens. 47 After Rep. McGee (now a Democratic legislator representing Salt Lake City) agreed to serve as the bill's chief sponsor, she and Larsen submitted a preliminary draft in November of 2004.48 In spite of the broad-based, bipartisan support it received, "the bill had the potential to generate serious controversy." 49 The stigma regarding GLBT homeless youths was likely to ward off members of the Legislature's conservative supermajority. But at the same time, the opportunities that queer homeless youths stood to gain from the bill drew support from GLBT advocates. 50 The bill received 4° See Woodruff, supra note 1; Simon & Townsend, supra note 4. HYRC S URVEY, supra note 19. 42 Id 43 1d. 44 Id. 45 Id. 46 Interview with Melissa Larsen, former Homeless Youth Policy Coordinator, Utah Pride Ctr., in Salt Lake City, Utah (Sept. 1, 2007). 47 Id. 48 Orton, supra note 13. 49 McGee, supra note 10. 50 Id.

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additional support from child welfare agencies like the Office of the Guardian ad Litem and from non-profit organizations like Volunteers of America.51 Additionally, because of the State's unique struggle with polygamy, the bill received strong support from the Utah Attorney General's Office and the Diversity Foundation.52 During the 2005 General Session, a number of legislators were "distracted by the idea of children in a tiff with their parents, angry over a trivial issue such as car privileges, who would seek emancipation." 53 Other legislators spoke of misguided teens using an emancipation law to "obtain abortions" or to "commit crimes such as fraud." 54 Proponents of the bill worked tirelessly to correct ill-conceived fears of youths attempting to "divorce" their parents haphazardly. After passing through the House of Representatives, misconceptions continued to stall the bill's progress, preventing it from being considered by the Senate before the closing of the session.55 Over the course of the year, Rep. McGee and Larsen continued to strategize, adding Representative Lorie Fowlke (a Republican attorney from Utah County) and Senator Curtis Bramble (a Republican member of the Senate Leadership) as cosponsors. 56 The bill was reintroduced for the 2006 General Session with even more support than it had the previous year. 57 The same arguments against the bill returned as well, but this time, Rep. Fowlke's added support provided a considerable advantage in correcting misconceptions about frivolous cases where youths might attempt to "divorce" their parents. 58 In the 2005 session, Rep. Fowlke defended the discretion given to juvenile courts, stating, "[t]he judges in juvenile court are bright men and women. They are not unaware that children may run away and make all sorts of claims—this bill is for the children who cannot get these necessary services without emancipation." 59 As a cosponsor to the bill in 2006, Rep. Fowlke garnered support from Republican colleagues behind the scenes while continuing to vocalize her support in the local media.6° During the 2006 legislative session, the bill moved quickly through the House of Representatives and into the Senate Judiciary, Law Enforcement, and Criminal Justice Committee, where it passed in spite of opposing testimony from a conservative lobbying group. 61 After a political amendment was added affirming

51 Larsen, supra note 46. 52 McGee, supra note 10. 53 Santini, supra note 13. 54 Id. 55 McGee, supra note 10. 56 Larsen, supra note 46. 571d.

58 McGee, supra note 10. 59 Amy Joi Bryson, Minors Could Soon Access Medical, Other Services Without Parents' OK, D ESERET MORNING NEWS, Feb. 26, 2005, at B6. 69 Adams, supra note 25 ("This is not about taking children away from their parents. This about children who do not have parents who care for them."). 61 Minutes of the Senate Judiciary, Law Enforcement, and Criminal Justice Standing Committee: Hearing on H.B. 30 Before the Law Enforcement, and Criminal Justice Standing Comm.

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the "fundamental liberty interest" of parents "in the care, custody, and management of their children," the bill passed the Senate and was signed by Utah Governor Jon Huntsman, Jr. on March 13, 2006.62 VI. THE EMANCIPATION LAW IN PRACTICE

The emancipation statute provides juvenile courts with the direction they need to emancipate a petitioning minor In comparison to similar statutes in other states, Utah's emancipation statute is fairly standard. Like Utah, most states require a minor petitioner to be at least sixteen years of age. 63 In addition, almost all statutes require petitioners to demonstrate their ability to live on their own and manage their own affairs. 64 The rights and responsibilities available under Utah's emancipation statute are consistent with most of the other state statutes as well.65 Some of these most basic legal authorizations include the ability to contract, to sue and be sued, to buy and sell property, to borrow money, and to obtain medical treatment without parental consent. The ability to contract is one of the most valuable rights afforded by Utah's emancipation statute because it allows youths to rent an apartment, to enter into an employment contract, and to obtain any healthcare services that may have previously required parental consent. 66 The statute also grants emancipated youths the power to manage their own finances, the right to control their own earning and property, and the ability to borrow money for school or necessary expenses.67 Essentially, these basic rights and responsibilities allow a significant portion of runaway and homeless youths to keep themselves from falling into a life on the streets. As Rep. Fowlke stated, "[w]henever a young person is in a place where

2006 Gen. Sess. (Utah 2007) (indicating that two members of the Eagle Forum spoke in opposition to the bill when the Committee opened the floor to public comments). 62 Larsen, supra note 46; H.B. 30, 2006-07 Leg., 2006 Gen. Sess. (Utah 2006) (enacted and codified as amended at UTAH CODE ANN. § 78-3a-1005 (2006)). 63 See, e.g., ALASKA STAT. § 9-55-590(a) (2006); CONN. GEN. STAT. § 46B-815t (2006); FLA. STAT. § 743.0 (2006); LA. CIV. CODE ANN. art. 3992 (2006); MONT. CODE ANN. § 41-3-4 (2006); N.M. STAT. § 32A-21-4 (2006); UTAH CODE ANN. § 78-3a-1003(1)(a) (2002 & Supp. 2007); VT. STAT. ANN. tit. 12, § 7151 (2006); WASH. REV. CODE § 13.64.050 (2006); W. VA. CODE § 49-7-27 (2006). But see ALA. CODE § 26-13-1-7 (2007); COLO. REV. STAT. § 19-1-103 (2006); TEX. CODE ANN. tit. 2, § 31.001 (2006); W YO. STAT ANN. § 14-1-101 (2006). 64 Compare UTAH CODE ANN. § 78-3a-1003 (2002 & Supp. 2007) with ALASKA STAT. § 9-55590(a) (2006); ILL. C OMP. STAT. 750/30-1 (2006); IND. CODE § 31-34-20-6 (2007); LA. C IV. CODE ANN. art. 3992 (2006); MONT. CODE ANN. § 41-3-4 (2006); N.M. STAT. § 32A-21-4 (2006); O R. REV. STAT. § 419B.552 (2006); TEX. CODE ANN. tit. 2, § 31.001 (2006); V T. STAT. ANN. tit. 12, § 7151 (2006); WASH. REV. CODE § 13.64.050 (2006); W YO. STAT ANN. § 14-1-101 (2006). 65 Compare UTAH CODE ANN. § 78-3a-1003 (2002 & Supp. 2007) with ILL. C OMP. STAT. 750/30-1 (2006); KAN. STAT. ANN. § 38-108 (2006); MONT. CODE ANN. § 41-3-4 (2006); WASH. REV. CODE § 13.64.050 (2006); W YO. STAT ANN. § 14-1-101 (2006). UTAH CODE ANN. § 78-3a-1005 (2002 & Supp. 2007). 67 Id.

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they have to emancipate, it is not usually a 'gain' but a management tool to try and move forward with a life that has obviously been very difficult to that point."68 A foreseeable criticism of the law, however, is that it requires the petitioner to show that he or she is capable of supporting him or herself, a task that often seems impossible for homeless youths. 69 This intentionally high standard exists to prevent the type of frivolous petitions articulated by the Utah State Legislature and to ensure the social and economic security of emancipated minors." But it is important to note that the bill does not preclude non-parental forms of support such as welfare funds and programs and loans that they cannot access as minors under the legal guardianship of their parents.'' While the Utah statute provides a complete process for homeless youths and runaways to seek emancipation, certain clauses in other state statutes may suggest possibilities for future improvement. Specifically, emancipation statutes in Montana and Vermont require minor petitioners to show that he or she is pursuing or will pursue a high school diploma or graduation equivalent. 72 By adding an educational component to the statute, the Legislature may emphasize the need for basic education and skills training. For practical reasons, statutes in Oregon, Washington, and Vermont also issue special driver's licenses or state identification cards to emancipated minors. 73 A requirement such as this would make it easier for emancipated minors to perform day-to-day activities in which they may need to verify their emancipated status. VII. CONCLUSION

Although Utah's Emancipation statute has been in effect for only sixteen months, the opportunities this bill presents for polygamist runaways and GLBT youths are already apparent. As of September, 2007, a total of ninety-eight petitions for emancipation have been considered in courts across the state of Utah. 74 Among these petitioners is Jenifer, a seventeen-year-old girl who escaped from the polygamist community in Colorado City in 2005. 75 After meeting the legal requirements for emancipation, she reflected on her newfound freedom stating, "[i]t has just opened up so many doors."76

68 E-mail from Rep. Lorie Fowlke, Utah House of Representatives, to author (Sept. 11, 2007, 10:44 MST) (on file with the author). 69 McGee, supra note 10. 70 Larsen, supra note 46. 71 McGee, supra note 10. 72 M ONT. C ODE ANN. § 41-3-4 (2006); V T. S TAT. ANN. tit. 12, § 7151 (2006). 73 M ONT. C ODE ANN. § 41-3-4 (2006); V T. S TAT. ANN. tit. 12, § 7151 (2006); W ASH. REV. C ODE § 13.64.050 (2006). 74 Disposition of Emancipation Cases 2006-07 (Aug. 31, 2007) (unpublished court statistics, on file with Administrative Office of the Courts). 75 Brooke Adams, Teen's Case Fits Lawmakers' Intent for Emancipation Law, SALT LAKE DUB., Dec. 16, 2006, available at http://children.safepassagefoundation.org/archives/2006/12/teens_ case_fits.html. 76 Id