Justia Arizona Supreme Court Opinion Summaries

In 1994, Christopher Spreitz was convicted by a jury of first-degree murder, sexual assault, and kidnapping of Ruby Reid. Reid was last seen leaving a bar in Tucson, and her body was found days later in a desert area. Spreitz admitted to hitting Reid with a rock to stop her from yelling. The medical examiner identified multiple injuries on Reid's body, including broken ribs, internal bleeding, and a skull fracture.The trial court found one aggravating circumstance: that Spreitz murdered Reid in an especially cruel manner. The court also considered several non-statutory mitigating factors, such as Spreitz's sub-normal home environment, emotional immaturity, lack of prior felonies, and potential for rehabilitation. The court determined that the aggravating circumstance outweighed the mitigating factors and sentenced Spreitz to death. This sentence was affirmed by the Arizona Supreme Court on direct appeal.Spreitz's petition for habeas corpus was denied by the federal district court, but a divided panel of the Ninth Circuit Court of Appeals reversed in part, concluding that the Arizona Supreme Court had applied an unconstitutional "causal nexus" test and did not properly consider evidence of Spreitz's longstanding alcohol and substance abuse as non-statutory mitigation. The Ninth Circuit remanded the case to the district court with instructions to correct the constitutional error or impose a lesser sentence.The Arizona Supreme Court conducted a new independent review of the entire record, including the mitigation evidence presented at the original sentencing. The court considered the mitigating factors without requiring a causal nexus to the murder and reweighed them against the established especially cruel aggravating circumstance. The court concluded that the mitigation evidence was insufficient to warrant leniency and affirmed the sentence of death. View "State v. Spreitz" on Justia Law

In January 2015, Ian Mitcham was arrested for DUI in Scottsdale, Arizona. He consented to a blood test to determine alcohol concentration or drug content, and two vials of blood were drawn. Mitcham was informed that the second vial would be destroyed if not claimed within ninety days, but it was not destroyed. Mitcham was later convicted of a misdemeanor DUI. In February 2015, Allison Feldman was found murdered, and DNA evidence was collected from the crime scene. In 2017, a familial DNA search linked Mitcham’s brother to the crime scene DNA, leading police to Mitcham. Without a warrant, police used the second vial of blood to create a DNA profile, which matched the crime scene DNA.The Maricopa County Superior Court suppressed the DNA evidence obtained from the second vial and the subsequent buccal swabs collected under a search warrant, ruling that the warrantless search violated the Fourth Amendment and no exceptions to the exclusionary rule applied. The court of appeals reversed, with the majority finding that the inevitable discovery and independent source exceptions applied, while a concurring judge found no Fourth Amendment violation.The Arizona Supreme Court reviewed the case and held that the police violated Mitcham’s Fourth Amendment rights by conducting a warrantless search of the second vial of blood. However, the court found that the inevitable discovery exception to the exclusionary rule applied. The court reasoned that Mitcham’s DNA profile would have inevitably been discovered through lawful means due to his subsequent felony convictions, which required DNA profiling under Arizona law. Therefore, the trial court erred in suppressing the DNA evidence. The Arizona Supreme Court reversed the trial court’s suppression order and remanded the case for further proceedings. View "STATE OF ARIZONA v MITCHAM" on Justia Law

A police officer from the City of Mesa, while driving his patrol car, was involved in a multi-vehicle accident that injured a bicyclist, Philip Rogers. Rogers claimed the officer's negligent driving caused the accident and served notices of claim to the City of Mesa and the officer, offering to settle for "$1,000,000 or the applicable [insurance] policy limits, whichever are greater." Later, Rogers amended his notices to specify a settlement amount of $1,000,000.The Superior Court of Maricopa County denied the City’s motion to dismiss Rogers' complaint, which argued that the initial notices did not comply with Arizona Revised Statutes § 12-821.01(A) because they did not state a specific settlement amount. The City then petitioned for special action review. The Court of Appeals reversed the Superior Court’s decision, directing it to dismiss the complaint, concluding that the notices of claim did not provide a specific amount for settlement as required by the statute.The Supreme Court of Arizona reviewed the case to determine if Rogers' notices of claim complied with § 12-821.01(A). The Court held that the settlement offer of "$1,000,000 or the applicable policy limits, whichever are greater" was insufficiently specific to meet the statutory requirements. The Court emphasized that the statute requires a clear and precise settlement amount, which was not provided in Rogers' notices. Consequently, Rogers was barred from maintaining his lawsuit due to non-compliance with the statutory notice requirements.The Supreme Court of Arizona reversed the Superior Court’s order and remanded the case with instructions to dismiss Rogers' claims. The Court also affirmed in part and vacated in part the opinion of the Court of Appeals. View "CITY OF MESA v. RYAN" on Justia Law

Preston Strong was convicted of six counts of first-degree murder and sentenced to death. Strong had a history of financial troubles and was friends with one of the victims, Luis Rios, who often loaned him money. An argument between Strong and Luis occurred about a month before the murders, with Luis refusing to loan Strong more money. On the day of the murders, Luis and Adrienne Heredia, along with her four children, were found dead in their home. Evidence included Strong’s fingerprints on plastic bags found at the scene and his DNA on the steering wheel of Luis’s vehicle.The Superior Court in Yuma County denied Strong’s motions to change the venue, suppress evidence, and dismiss the case due to preindictment delay. The jury found Strong guilty and determined that the State had proved the alleged aggravating circumstances. The trial court later instructed the jury to disregard one of the aggravating factors during the penalty phase. Strong’s motions for a new trial and to vacate the judgment, based on alleged juror misconduct and other grounds, were denied.The Arizona Supreme Court reviewed the case and affirmed Strong’s convictions and sentences. The court found no abuse of discretion in the trial court’s rulings on preindictment delay, change of venue, and the admission of evidence. The court also concluded that the trial court did not err in its handling of juror misconduct allegations, the admission of DNA evidence, and the consideration of victim impact statements. The court held that the erroneous instruction regarding the cold-and-calculating aggravating factor did not constitute fundamental error, as the jury was instructed to disregard it. The court also found that the jury’s findings of aggravating circumstances and the imposition of the death penalty were supported by reasonable evidence and did not violate constitutional standards. View "STATE OF ARIZONA v STRONG" on Justia Law

David Francisco, a retired endodontist, sought treatment from Dr. Kevin Art of Affiliated Urologists, Ltd. in 2018. Dr. Art performed a urological procedure and prescribed the antibiotic Ciproflaxin (Cipro) without discussing its use with Francisco. The FDA's black box warning for Cipro indicated serious risks, especially for elderly patients with a history of corticosteroid use, which applied to Francisco. After taking Cipro, Francisco experienced severe adverse reactions, including tendon ruptures and peripheral neuropathy.The Superior Court in Maricopa County dismissed the Franciscos' case for failing to provide a preliminary expert opinion affidavit as required by A.R.S. § 12-2603. The Franciscos argued that the FDA warning itself should establish the standard of care, negating the need for expert testimony. The Court of Appeals reversed the dismissal, holding that the FDA warning could be sufficient to establish the standard of care without expert testimony.The Arizona Supreme Court reviewed the case and held that FDA warnings cannot substitute for expert testimony to establish the standard of care in medical malpractice cases. The Court emphasized that medical judgment is required to determine the appropriate standard of care, which must be established by expert testimony. The Court also rejected the Franciscos' argument that the statutory requirements for expert testimony violated the anti-abrogation clause of the Arizona Constitution, finding that the statutes permissibly regulate medical negligence actions.The Arizona Supreme Court vacated the Court of Appeals' decision and affirmed the Superior Court's dismissal of the case. View "FRANCISCO v AFFILIATED UROLOGISTS" on Justia Law

In this case, the appellant, Christopher Montoya, was convicted of first-degree murder, second-degree burglary, kidnapping, aggravated identity theft, unlawful use of means of transportation, theft, and two counts of animal cruelty. Montoya was sentenced to death for the murder charge. The crimes occurred after Montoya's relationship with the victim, A.R., ended, leading him to break into her house, attack, and ultimately kill her. Montoya also used A.R.'s personal information and belongings for his benefit after her death.The Superior Court in Maricopa County handled the initial trial, where Montoya pleaded guilty to all charges and admitted to two capital aggravators: committing previous serious offenses and murdering A.R. in an especially cruel and heinous manner. Despite his guilty plea, Montoya waived the presentation of most mitigation evidence, allowing only the records of his guilty pleas and mitigation waiver hearings to be submitted as evidence of his acceptance of responsibility. The jury returned a death verdict, and the court sentenced Montoya to death for the murder and to a combined 103 years in prison for the other charges.The Supreme Court of the State of Arizona reviewed the case. The court affirmed Montoya’s convictions and sentences, including the death penalty. The court found no fundamental errors in the trial process, including the handling of voir dire, the admission of autopsy photographs, and the acceptance of Montoya’s waiver of mitigation evidence. The court also determined that the jury instructions were adequate and that the victim impact statements did not fundamentally prejudice Montoya’s right to a fair trial. The court conducted an independent review of the death sentence and concluded that a reasonable jury could have found the mitigating circumstances insufficient to warrant leniency. View "STATE OF ARIZONA v MONTOYA" on Justia Law

Marcos Martinez killed his grandmother and subsequently pleaded guilty except insane (GEI) to first-degree murder. Under his plea agreement, he was committed to the Arizona State Hospital and will remain under the jurisdiction of the superior court for life. However, unlike a standard guilty plea, Martinez’s GEI plea did not include restitution for the victims of his crime. Lisa Gilpin, claiming to be a victim, sought approximately $18,300 in restitution from Martinez under Arizona’s Victims’ Bill of Rights (VBR). The superior court denied her request, citing the precedent set in State v. Heartfield, which held that GEI defendants are not responsible for restitution.The superior court ruled that a GEI judgment is not a “conviction” for restitution purposes, thus making restitution unavailable. Gilpin sought special action review from the Arizona Court of Appeals, Division Two, but the court declined jurisdiction. The Arizona Supreme Court granted review due to the recurring statewide importance of whether crime victims are entitled to restitution from GEI defendants.The Arizona Supreme Court overruled Heartfield, concluding that the legislature intended to assign criminal responsibility to GEI defendants. The court held that a GEI verdict results in criminal responsibility, and therefore, victims are entitled to restitution from GEI defendants who cause or threaten to cause death or serious bodily injury. The court remanded the case to the superior court to determine Gilpin’s eligibility for restitution, the amount owed, and whether Martinez is liable for restitution payments while suffering from a mental disease or defect. View "GILPIN v MARTINEZ" on Justia Law

In 2016, Bennett Laquan Williams was charged with fourteen felonies, including sex trafficking and various misdemeanors. The State alleged he was on probation and had seven prior felony convictions, including a 2004 Arizona marijuana conviction. Williams entered a plea agreement, pleading guilty to two counts of sex trafficking as a repeat offender, in exchange for a twelve-year sentence and the dismissal of other charges and allegations.The Superior Court accepted the plea and sentenced Williams to twelve years. In 2020, Arizona voters passed Proposition 207, allowing for the expungement of certain marijuana convictions. Williams successfully expunged his 2004 marijuana conviction and subsequently filed for post-conviction relief, arguing that his sentence was invalid without the prior marijuana conviction. The Superior Court dismissed his petition, but the Court of Appeals reversed, vacated the plea agreement, reinstated the original charges, and remanded the case.The Arizona Supreme Court reviewed the case and agreed that Williams was entitled to post-conviction relief due to the expungement of his marijuana conviction, which invalidated the factual basis for his enhanced sentence. However, the Court found that the Court of Appeals erred in voiding the plea agreement entirely. Instead, the Supreme Court held that the plea agreement is voidable, not void, if Williams is resentenced to a term different from the agreed twelve years. If resentenced to less than twelve years, the State may withdraw from the agreement; if resentenced to more, Williams may withdraw his plea.The Supreme Court vacated parts of the Court of Appeals' opinion, affirmed the remainder, reversed the Superior Court's order, and remanded the case for resentencing. The State cannot allege a different prior conviction under the existing plea agreement. View "STATE OF ARIZONA v WILLIAMS" on Justia Law

The case involves a dispute over the constitutionality of "release time" provisions in a memorandum of understanding (MOU) between the City of Phoenix and the American Federation of State, County, and Municipal Employees, Local 2384. These provisions allow certain employees to be released from their regular duties, while still being paid by the City, to perform union activities. The plaintiffs, who are non-union employees, argued that these provisions violate their free-speech, free-association, and right-to-work rights, as well as the Gift Clause of the Arizona Constitution.The Superior Court in Maricopa County granted summary judgment in favor of the City and the Union, finding that the release time provisions did not violate the plaintiffs' constitutional rights because the City, not the employees, paid for the release time. The court also found that the provisions did not violate the Gift Clause, as they served a public purpose and were supported by adequate consideration. The plaintiffs appealed, and the Court of Appeals affirmed the lower court's decision, agreeing that the provisions did not violate the plaintiffs' rights and were supported by adequate consideration.The Arizona Supreme Court reviewed the case and concluded that the release time provisions do not violate the free-speech, free-association, or right-to-work rights of the plaintiffs because the City pays for the release time. However, the Court found that the provisions violate the Gift Clause of the Arizona Constitution. The Court determined that the release time provisions do not provide adequate consideration to the City, as the benefits to the City are negligible compared to the substantial costs. Consequently, the Court vacated the Court of Appeals' opinion, reversed the Superior Court's decision, and remanded the case for the entry of judgment in favor of the plaintiffs on the Gift Clause claim. View "GILMORE v. GALLEGO" on Justia Law

In 2018, Kevin Moninger, a Nevada resident, posted classified ads on a website for sexual encounters. He received a response from "Sabrina," a fictional 13-year-old girl created by an undercover officer. Over several days, Moninger exchanged explicit messages with Sabrina, discussing sexual activities and planning to meet. On October 5, Moninger drove to Kingman, Arizona, to meet Sabrina but was arrested upon arrival. He was charged with three counts of luring a minor for sexual exploitation and one count of attempted sexual conduct with a minor.The Superior Court in Mohave County convicted Moninger on all charges, sentencing him to four consecutive prison terms totaling 31 years. Moninger appealed, and the Arizona Court of Appeals vacated two of his three luring convictions, ruling that his conduct constituted a single violation of the statute, thus subjecting him to double jeopardy. The court remanded the case for resentencing on the remaining luring conviction and held that it should be considered probation eligible. A dissenting judge argued that each request for sexual conduct was a separate harm and that Moninger's convictions were not probation eligible.The Arizona Supreme Court reviewed the case to clarify the allowable unit of prosecution under A.R.S. § 13-3554. The court held that luring a minor for sexual exploitation is based on a course of conduct defined by offers or solicitations of separate and distinct sexual conduct or to separate and distinct victims. The court found that Moninger's actions constituted a single course of conduct involving one type of sexual conduct with one victim, thus supporting only one luring conviction. The court vacated Moninger's second and third luring convictions and remanded the case for resentencing on the remaining conviction, which was deemed not probation eligible under A.R.S. § 13-705(H) (2018). View "STATE OF ARIZONA v MONINGER" on Justia Law