Justia Arizona Supreme Court Opinion Summaries

Douglas Eddington was charged as an accomplice in the murder of the son of a Tucson police officer. During voir dire, one potential juror stated he was employed as a deputy sheriff with the law enforcement agency that had investigated the crime. The trial court denied Eddington's motion to strike the deputy for cause, and the jury ultimately found Eddington guilty of second degree murder. The court of appeals held that the trial court erred in refusing to strike the deputy. The Supreme Court affirmed, holding that a peace officer currently employed by the law enforcement agency that investigated the case is an "interested person," who is disqualified from sitting as a juror by Ariz. Rev. Stat. 21-211(2). View "State v. Eddington" on Justia Law

Michael Hummons agreed to speak with a police officer on the sidewalk. During the encounter the officer discovered an outstanding warrant for Hummons' arrest. The officer arrested Hummons, and in a search incident to that arrest discovered drugs and drug paraphernalia in Hummons' backpack. At trial Hummons moved to suppress the evidence, arguing it was obtained as the result of an illegal detention. The trial court denied the motion, finding the officer's encounter with Hummons consensual. The court of appeals affirmed. The Supreme Court vacated the judgment of the appellate court, holding that the court overemphasized the importance the warrant as an intervening circumstance in dissipating the taint of any prior illegality and that the court should have applied the third Brown v. Illinois factor, i.e., the purpose and flagrancy of the official misconduct. The Court held the totality of the circumstances militated against suppressing the evidence and upheld the judgment of the trial court.View "State v. Hummons" on Justia Law

After Petitioner was indicted on child abuse, the State extended a plea offer in May 2009 without imposing a deadline for its acceptance. A new prosecutor was assigned to the case in August 2009 and notified Petitioner that the offer was no longer available. Petitioner moved under Ariz. R. Crim. P. 15.8, which authorizes sanctions if a prosecutor imposes a plea deadline and fails to disclose certain information to the defense at least thirty days before the offer lapses, to preclude any evidence disclosed after July 29, 2009. The trial court denied the motion. The court of appeals granted relief to Petitioner, holding that rule 15.8 applied because the State effectively imposed a deadline on the offer by withdrawing it. The Supreme Court vacated the court of appeals, holding (1) rule 15.8 does not apply when a prosecutor withdraws an open-ended plea offer; and (2) in such a situation, Ariz. R. Crim. P. 15.7 governs the imposition of sanctions for any failure to make required disclosures. Remanded. View "Rivera-Longoria v. Superior Court (Slayton)" on Justia Law

Defendant Scott Lehr was convicted of first degree murder and sentenced to death for the murder of two women. On appeal, the Supreme Court affirmed Lehr's convictions and sentences, holding (1) Lehr's waiver of his right to attend trial was knowing and voluntary; (2) the trial court did not err in its use of other acts evidence and in its jury instructions; (3) the trial court did not violate Lehr's rights under the Confrontation Clause in admitting prior testimony by a witness; (4) the trial court did not abuse its discretion in denying Lehr's motion to preclude DNA evidence; (5) the trial court did not deny Lehr's right to a fair and impartial jury by refusing to grant a mistrial after several jurors applauded upon the completion of certain testimony; (6) the trial court's jury instruction defining premeditation and the State's closing argument did not violate Lehr's right to due process; (7) the trial court did not violate the state rules of criminal procedure by allowing the State to amend its notice of aggravating factors; and (8) the trial court did not violate the Eighth Amendment by precluding Lehr from offering testimony from one of his victims. View "State v. Lehr" on Justia Law

A jury found James Styers guilty of the 1989 murder, conspiracy to commit first degree murder, kidnapping, and child abuse of a four-year-old. After finding three aggravating factors and no mitigating circumstances, the trial judge sentenced Styers to death. The Supreme Court affirmed the sentence. Styers then filed a habeas corpus petition, which the district court denied. The court of appeals reversed and granted relief, finding that in independently reviewing Styers' death sentence, the Supreme Court erroneously refused to consider as a mitigating circumstance the PTSD Styers suffered from as a result of military service in Vietnam. The Supreme Court granted the state's request to conduct a new independent review. On review, the Court affirmed Styers' sentence, holding that Styers' PTSD, in combination with all other mitigating evidence previously considered by the Court, was not sufficient to warrant leniency in light of the aggravating factors proven in this case. View "State v. Styers" on Justia Law