Justia Arizona Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of first degree felony murder and six other felonies for offenses committed during a home invasion. The trial court imposed death sentences for the murders and prison sentences totaling seventy-five years for the non-capital counts. The Supreme Court affirmed Defendant’s convictions and sentences but ordered that her sentences for armed robbery and aggravated robbery run concurrently, holding, among other things, that (1) the trial court did not commit reversible error in granting Defendant’s motion for a change of venue based on extensive media coverage of the crimes, deciding its rulings regarding jury selection, and instructing the jury; (2) the prosecutor did not commit misconduct; and (3) the trial court erred in imposing consecutive sentences for robbery and aggravated robbery because these crimes were based on a single act by Defendant. View "State v. Forde" on Justia Law

After a jury trial, Defendant was convicted of five counts of first degree murder, among other charges, and sentenced to death for each murder. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) Defendant was not deprived of his right to a speedy trial; (2) the trial court did not abuse its discretion by consolidating the murder and solicitation of first degree murder charges; (3) the trial court did not err in admitting into evidence certain victims’ recorded statements; (4) the trial court did not err in denying Defendant’s motion for mistrial; (5) the trial court did not err in admitting a forensic firearms expert’s testimony; (6) substantial evidence supported the solicitation convictions; (7) the trial court did not err in its jury instructions; (8) and substantial evidence supported the jury’s findings of aggravating circumstances and the imposition of the death sentences. View "State v. Miller" on Justia Law

After a jury trial, Appellant was convicted of two counts of first degree murder and thirty counts of attempted first degree murder following a shooting spree at a homeowners' association meeting in 2000. Appellant was sentenced to death. The Supreme Court affirmed the convictions and sentences on appeal. In 2010, Appellant filed a petition for post-conviction relief. The petition was pending when Appellant died in 2013. The superior court subsequently dismissed Appellant's post-conviction relief proceeding as well as his indictment and conviction under State v. Griffin, in which the Supreme Court held that when a convicted defendant dies before his direct appeal is decided, the prosecution is abated from the outset, and the conviction is set aside. The Supreme Court vacated the superior court's judgment, holding that the doctrine of abatement ab initio set forth in Griffin does not apply when a defendant dies after his conviction is affirmed but while post-conviction relief proceedings are pending. View "State v. Glassel" on Justia Law

Defendant was charged with four felonies relating to an assault. After Defendant agreed to plead guilty to a lesser charge, he admitted at a change-of-plea hearing that he was an accomplice. Later Defendant denied any involvement. The trial court subsequently rejected the plea agreement. During the trial proceedings, Defendant moved to prevent the State from using statements he made during the change-of-plea hearing. The trial court ruled that the State could impeach Defendant with his statements if he testified inconsistently with them at trial. Defendant did not testify at trial, and the jury found him guilty on all counts. The Supreme Court affirmed, holding (1) the trial court erred in ruling the State could use Defendant's change-of-plea statements to impeach him; but (2) Defendant could not raise the trial court's error on appeal because a defendant must testify to preserve a challenge to a ruling permitting the use of evidence for impeachment. View "State v. Duran" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, armed robbery, first degree burglary, kidnapping, and theft of a means of transportation. The trial court sentenced Defendant to death for the murder conviction and to prison sentences totaling forty-two years for the other convictions. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not abuse its discretion in declaring a mistrial and later denying Defendant's motion to dismiss the State's allegation that Defendant should be sentenced to death; (2) the statutes governing the death penalty are not unconstitutionally vague; (3) there is not an unconstitutional presumption of death in Arizona's death penalty statutes; and (4) the jury did not abuse its discretion in imposing the death sentence in this case. View "State v. Reeves" on Justia Law

After a jury trial, Defendant was convicted of first degree murder, third degree robbery, and aggravated robbery. Defendant was sentenced to death for the murder. A few years later, the trial court vacated the sentence, finding that Defendant's defense counsel was inefficient. Because the jury could not agree on a sentence at the resentencing trial, the judge declared a mistrial. After a second penalty phase trial, the jury determined Defendant should be sentenced to death. The Supreme Court affirmed Defendant's death sentence, holding, inter alia, that (1) the trial court did not abuse its discretion in denying Defendant's second petition for post-conviction relief and his motion to suppress; (2) the statutory provision for retrial after a hung penalty-phase jury does not result in cruel and unusual punishment; (3) the trial court did not err in its decisions regarding the jury or the jury instructions; (4) the application of the 2009 version of Ariz. Rev. Stat. 13-752(G) in Defendant's case did not violate the ex post facto clause; (5) the prosecutor did not commit misconduct; and (6) based on the aggravating and mitigating circumstances present in this case, the mitigation was not sufficiently substantial to warrant leniency. View "State v. Medina" on Justia Law

After a jury trial, Defendant was convicted of three counts of child abuse, two counts of concealing a dead body, and two counts of first degree murder. The jury also found three aggravating factors, including the young age of the victims, ages three and four. Defendant was sentenced to death for the two murders. The Supreme Court affirmed Defendant's convictions and sentences, holding, inter alia, that (1) the trial court did not err by dismissing some jurors improperly and failing to dismiss others; (2) the trial court did not err by denying Defendant's request for a change of venue based on presumed and actual prejudice; (3) the trial court did not err by refusing to suppress Defendant's post-arrest statements; (4) the prosecution did not commit prejudicial misconduct; (5) the evidence was sufficient to convict Defendant of the child abuse charges; (6) the trial court did not fundamentally err in its aggravation phase jury instructions; and (7) the jury did not abuse its discretion by finding the mitigating factors presented by Defendant insufficient to warrant leniency. View "State v. Payne" on Justia Law

After a jury trial, Defendant was convicted of the murders of three individuals and of attempted murder. Defendant was sentenced to death for each murder. The Supreme Court affirmed, holding, inter alia, that (1) the trial court sufficiently inquired into the bases for Defendant's requests for a change of counsel and correctly denied the requests; (2) the trial court did not err in refusing to permit Defendant to impeach the surviving victim with her prior inconsistent statements absent an offer of proof of the prior statements; (3) the trial court did not err in admitting evidence impeaching a witness as substantive evidence of Defendant's guilt; (4) the State presented sufficient evidence of premeditation; and (5) the jury did not abuse its discretion by determining that the mitigation presented by Defendant was not sufficiently substantial to call for leniency. View "State v. Hernandez" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree murder and eight other felonies. For his crimes, Defendant was sentenced to death and prison terms. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not abuse its discretion in its pretrial rulings; (2) the trial court did not err in instructing the jury during the aggravation phase; (3) the prosecutor did not misstate the law in his closing argument; (4) the trial court did not abuse its discretion in refusing to inform the jury of Defendant's willingness to waive parole eligibility; (5) the trial court did not abuse its discretion in excluding victim impact evidence; (5) the jury's finding that three aggravating circumstances applied was supported by the evidence with respect to each murder; and (6) the jury did not abuse its discretion in imposing the death penalty for each murder. View "State v. Benson" on Justia Law

This case involved the intersection of municipal zoning regulations and the right of tattoo artists to ply their trade. After the City of Mesa denied Plaintiffs a permit to operate a tattoo parlor, Plaintiffs filed this action alleging violations of their rights to free speech, due process, and equal protection. The superior court dismissed the complaint for failing to state a claim upon which relief can be granted. Recognizing that tattooing involves constitutionally protected speech, the Supreme Court vacated the court of appeals and reversed the judgment of the superior court, holding that the superior court erred by dismissing the complaint as a matter of law. Remanded. View "Coleman v. City of Mesa" on Justia Law