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

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

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

The Supreme Court of the State of Arizona considered whether the Arizona Legislature repealed or otherwise restricted A.R.S. § 13-3603 by enacting the abortion statutes in Title 36, specifically A.R.S. § 36-2322, which prohibits physicians from performing elective abortions after fifteen weeks’ gestation. The case arose from a motion for relief under Arizona Rule of Civil Procedure 60(b)(5)–(6), seeking to set aside the permanent injunction against § 13-3603 imposed in 1973 following the U.S. Supreme Court's decision in Roe v. Wade.Previously, the trial court granted the motion, vacating the judgment in its entirety to allow full enforcement of § 13-3603. The court of appeals reversed, concluding that licensed physicians who perform abortions in compliance with Title 36 are not subject to prosecution under § 13-3603.The Supreme Court of the State of Arizona held that § 36-2322 does not create a right to, or otherwise provide independent statutory authority for, an abortion that repeals or restricts § 13-3603. The court concluded that absent the federal constitutional abortion right, and because § 36-2322 does not independently authorize abortion, there is no provision in federal or state law prohibiting § 13-3603’s operation. Accordingly, § 13-3603 is now enforceable. The court affirmed the trial court’s judgment vacating the injunction of § 13-3603, vacated the court of appeals’ opinion and stay of enforcement of § 13-3603, and remanded to the trial court for potential consideration of the remaining constitutional challenges to §13-3603 alleged in Planned Parenthood’s complaint for declaratory relief. View "Planned Parenthood v. Mayes" on Justia Law

In Arizona, condominium unit owners Jie Cao and Haining Xia challenged the forced sale of their unit by their condominium association (the “Association”) following the dissolution of the condominium. The Association, which had been given power to sell under the Arizona Condominium Act, sold the unit to PFP Dorsey Investments, a company that had previously acquired the majority of units in the condominium.The Supreme Court of the State of Arizona held that the Arizona Condominium Act, which authorized the sale, did not violate the eminent domain provision of the Arizona Constitution. The court stated that the Act was incorporated into the condominium declaration, to which the owners had agreed. However, the court also held that in these circumstances, the Act required the sale of all property, rather than individual units as occurred in this case.The court noted that the Association's power to sell derived from the condominium declaration that all unit owners had signed. Thus, the Act didn't effect a taking of the owners' property. As such, the forced sale of the owners’ unit alone rather than as part of a sale of all common elements and units of the condominium was impermissible under the Act.The court vacated the court of appeals’ decision and remanded the case to the trial court for further proceedings consistent with its opinion. The court also granted the owners reasonable attorney fees for amounts expended to enforce the Declaration, excluding those attributable to the unsuccessful eminent domain claims. View "CAO v PFP DORSEY" on Justia Law

In this case, the Supreme Court of the State of Arizona addressed two key issues related to the City of Scottsdale's decision not to award a license to operate competitive youth swimming programs at its public aquatic centers to Neptune Swimming Foundation, despite Neptune submitting a financially lucrative proposal through a request-for-proposal (RFP) process. Instead, the City chose to extend an existing license agreement with Scottsdale Aquatic Club (SAC), which had operated programs at the centers for over fifty years.The court first addressed whether a bid from a higher bidder should be considered when determining whether the City violated the Arizona Constitution's Gift Clause, which prohibits public entities from making donations or grants to any individual, association, or corporation. The court held that the higher bid in the RFP process was relevant, but not conclusive, in determining the fair market value of the license. A public entity does not necessarily violate the Gift Clause by choosing a less profitable arrangement. The court affirmed the lower court's summary judgment in favor of the City on this issue.The second issue was whether the City abused its discretion by failing to follow its own procurement process rules when it canceled the RFP and extended SAC's existing license agreement. The court found that there were material factual disputes about whether the City violated its own procurement process, which should have precluded summary judgment for the City on this issue. The court therefore reversed the lower court's summary judgment in favor of the City on this issue and remanded the case for further proceedings. View "NEPTUNE SWIMMING FOUNDATION v CITY OF SCOTTSDALE" on Justia Law

In the case before the Supreme Court of the State of Arizona, Phoenix Police Sergeant Stefani McMichael-Gombar appealed against her suspension for posting content on Facebook that violated the Phoenix Police Department’s Social Media Policy. She argued that the policy was overbroad and violated the First Amendment to the U.S. Constitution, or that she reasonably believed she had a First Amendment right to make the post. The Phoenix Civil Service Board upheld the suspension, and McMichael-Gombar sought relief in the superior court. The superior court dismissed her complaint, stating that the Phoenix City Charter neither requires nor authorizes the Board to consider the constitutionality of the City’s policies, and this is only tasked with determining if the allegations against an employee are true and if the level of discipline was appropriate. The court of appeals vacated this ruling, determining that the Board must consider whether the disciplinary action properly regards McMichael-Gombar’s constitutional rights.The Supreme Court of the State of Arizona affirmed the superior court’s decision, holding that the Board does not have the authority to decide whether a city policy is unconstitutional, as this power is not explicitly granted to it by the Phoenix City Charter, the rules governing disciplinary proceedings, or the Peace Officers Bill of Rights. However, the court did agree that McMichael-Gombar was entitled to argue and introduce supporting evidence that she reasonably believed she was acting within her First Amendment rights. The court concluded that McMichael-Gombar did not meet her burden to show that the Board precluded her from doing so. Thus, the court vacated the court of appeals’ opinion and affirmed the superior court’s order dismissing McMichael-Gombar’s special action complaint. View "MCMICHAEL-GOMBAR v PHOENIX CIVIL SERVICE" on Justia Law

The Supreme Court held that the "anti-abrogation clause" set forth in Ariz. Const. art. XVIII, 6 guaranteeing that the "right of action to recover damages for injuries shall never be abrogated" does not extend to dram-shop actions because they were recognized after statehood.At issue was whether the anti-abrogation clause extends to rights of action created after the Arizona Constitution was ratified, such as the common law dram-shop action recognized in Ontiveros v. Borak, 136 Ariz. 500 (1983). Plaintiffs sued Defendant, the owner of Jaguars Club in Phoenix, under theories of statutory and common law dram-shop liability. The jury found Defendant was liable under the common law dram-shop action recognized in Ontiveros but not liable under the dram-shop cause of action codified at Ariz. Rev. Stat. 4-311(A). The jury apportioned forty percent of the fault to Defendant. The Supreme Court remanded the case to the trial court for entry of judgment in favor of Defendant, holding that the legislature's limitation of dram-shop liability to actions brought under section 4-311 did not run afoul of the anti-abrogation clause by abrogating the common law dram-shop action recognized in Ontiveros. View "Torres v. JAI Dining Services, Inc." on Justia Law

In this murder case, the Supreme Court established a standard a defendant must satisfy to compel extraction of GPS data by a defendant's third-party agent from a crime victim's automobile for the trial court's in camera inspection and held that remand was required in the instant case.Defendant was charged with the second-degree murder of Grant Draper, making his brother Lane Draper a victim by virtue of Ariz. Rev. Stat. 13-4401(12), a statute that implements the Arizona Constitution's Victims' Bill of Rights. During plea negotiations and without notice to Lane, Defendant obtained a court order to access GPS data to support his third-party defense identifying Lane as the possible killer and for cross-examination regarding the time Defendant argued he was asleep. The trial court allowed the data to be extracted for a limited in camera interview. Lane filed a petition for special action, which the court of appeals denied. The Supreme Court held (1) a defendant is entitled to discovery from a victim if the defendant seeks evidence of a constitutional dimension and the defendant establishes that the requested discovery is very likely to contain such evidence; and (2) remand was required in this case. View "Draper v. Honorable Gentry" on Justia Law