Justia Arizona Supreme Court Opinion Summaries

The case concerns a challenge by the leaders of the Arizona Senate and House of Representatives to the Voters’ Right to Know Act, a voter-approved initiative that imposes new campaign finance disclosure requirements and grants broad enforcement powers to the Citizens Clean Elections Commission. The legislative leaders argue that the Act unconstitutionally delegates legislative authority to the Commission, an executive agency, and that the challenged provisions are so integral to the Act that, despite a severability clause, their invalidity would render the entire measure void.After the Act was approved by voters, the legislative leaders, authorized by their respective chambers, filed a facial constitutional challenge in the Superior Court of Maricopa County against the Secretary of State and the Commission. The Arizona Attorney General and the political action committee that sponsored the Act intervened to defend it. The superior court denied the leaders’ motion for a preliminary injunction, finding no specific injury had occurred, and also denied the defendants’ motions to dismiss, allowing the leaders to amend their pleadings. On appeal, the Arizona Court of Appeals held that the leaders lacked standing to challenge the entire Act but had standing to challenge a specific provision (§ 16-974(D)) that prevented the Legislature from limiting the Commission’s rules or enforcement actions. The court of appeals found this provision unconstitutional but severable, and enjoined its enforcement while upholding the rest of the Act.The Supreme Court of the State of Arizona reviewed the case and held that the legislative leaders have standing to challenge the Act, as the alleged unconstitutional delegation of legislative power constitutes an institutional injury. However, the Court determined that it is premature to address the severability of the challenged provisions before a ruling on their constitutionality. The Supreme Court reversed the superior court’s decision, vacated the court of appeals’ decision, and remanded the case for further proceedings. View "Montenegro v. Fontes" on Justia Law

The case concerns a defendant who was indicted on multiple counts of sexual conduct with a minor and one count of public sexual indecency to a minor. The State made a plea offer that would have capped his sentence at 27 years, but his trial counsel failed to adequately communicate the offer or explain the sentencing consequences if he went to trial. The defendant only learned the full extent of his potential sentence immediately before trial and attempted to accept the plea, but the offer had expired. He was convicted on all counts and sentenced to 79.5 years in prison.After his conviction was affirmed on direct appeal by the Arizona Court of Appeals, the defendant filed a timely first petition for post-conviction relief (PCR) in the Maricopa County Superior Court, raising ineffective assistance of counsel (IAC) claims but not specifically focusing on the plea offer issue. His PCR counsel chose not to pursue that claim, and the petition was denied. Subsequent federal habeas proceedings were also unsuccessful. Years later, the defendant filed a successive PCR petition, this time specifically alleging IAC related to the plea offer. The Superior Court found the claim was not precluded and excused the untimeliness, but the Court of Appeals reversed, holding the claim was precluded under prior Arizona Supreme Court precedent.The Supreme Court of Arizona reviewed whether the successive IAC claim was precluded and whether the untimely filing was excusable. The court held that a claim based on counsel’s failure to adequately communicate a plea offer implicates a constitutional right of such magnitude—the right to decide whether to plead guilty and waive a jury trial—that it can only be waived knowingly, voluntarily, and personally by the defendant. Therefore, the claim was not precluded. The court also held that the defendant adequately explained the delay, so the untimely filing was excused. The Supreme Court affirmed the Superior Court’s rulings on preclusion and timeliness, vacated part of the Court of Appeals’ opinion, and remanded for further proceedings. View "STATE OF ARIZONA v TRAVERSO" on Justia Law

In 2010, an inmate killed his cellmate in an Arizona state prison, inflicting fatal blunt and sharp force injuries. The defendant was convicted by a jury of premeditated first degree murder. The jury found three statutory aggravating factors: a prior conviction for a serious offense, the especially heinous or depraved manner of the crime, and that the offense was committed while in the custody of the state department of corrections. The jury determined that death was the appropriate sentence.The Arizona Supreme Court previously reviewed the case in 2017, affirming the conviction and the findings in the aggravation phase, but vacating the death sentence and remanding for a new penalty phase to comply with United States Supreme Court precedent regarding jury instructions on parole ineligibility. On remand, the defendant waived his right to counsel and to present mitigating evidence, a waiver the trial court found to be knowing, intelligent, and voluntary. The penalty phase was conducted with the defendant representing himself, assisted by advisory counsel, but he did not present any mitigating evidence or argument. The jury again returned a death verdict, and the superior court imposed the sentence.The Supreme Court of the State of Arizona reviewed the case on automatic appeal. The court held that the trial court erred by permitting the defendant to be visibly restrained before the jury without making case-specific findings as required by Deck v. Missouri, but found that this error was not fundamental and did not prejudice the outcome, given the overwhelming aggravating evidence and the defendant’s own choices. The court also held that the defendant’s waiver of mitigation was valid and that the trial court was not required to present mitigating evidence over his objection. The court found no abuse of discretion in the jury instructions, no fundamental error in declining to define “moral culpability,” and no prosecutorial error. The Arizona Supreme Court affirmed the death sentence. View "STATE OF ARIZONA v RUSHING" on Justia Law

The case involves the Arizona Abortion Access Act Initiative I-05-2024, which appeared on the November 5, 2024, general election ballot. The Legislative Council prepared an analysis of the initiative, which included a description of existing state law prohibiting abortions after 15 weeks of gestation, except in medical emergencies. The analysis used the term "unborn human being" to describe the existing law, which the initiative's proponents argued was not impartial and requested the term "fetus" be used instead.The Superior Court in Maricopa County ruled in favor of the initiative's proponents, finding that the term "unborn human being" was emotionally and partisanly charged, and ordered the Council to replace it with a neutral term. The Council members appealed the decision, arguing that the analysis was impartial and complied with statutory requirements.The Arizona Supreme Court reviewed the case and reversed the Superior Court's ruling. The Court held that the analysis substantially complied with the statutory requirement for impartiality by accurately describing existing law using the precise terminology found in the statute. The Court emphasized that the term "unborn human being" is used in the existing law and that the analysis provided necessary background information to voters. The Court concluded that the analysis was impartial and did not advocate for or against the initiative. The request for attorney fees and costs by the initiative's proponents was denied. View "ARIZONA FOR ABORTION ACCESS v MONTENEGRO" on Justia Law

Giovani Fuster Melendez moved from Puerto Rico to Arizona in 2017 and became acquainted with the victim, A.G., through a church connection. In 2019, Melendez returned to his former apartment complex, encountered A.G., and fired multiple shots at him, missing each time. Melendez was taken into custody shortly after the incident. During his police interview, he was read his Miranda rights twice and initially chose not to speak. However, in a subsequent interview, he deferred answering some questions but eventually confessed to the shooting, claiming self-defense.The Superior Court in Maricopa County convicted Melendez of aggravated assault and five counts of endangerment, sentencing him to concurrent prison terms. On appeal, the Arizona Court of Appeals found that the State's references to Melendez's selective silence during his police interview violated his constitutional rights, constituting fundamental prejudicial error.The Arizona Supreme Court reviewed the case to determine if the State violated Melendez's due process rights by commenting on his post-Miranda statements and temporary deferrals during the trial. The Court held that the State could use a defendant’s post-Miranda statements and temporary deferrals for impeachment purposes if the defendant did not unambiguously invoke his Miranda rights and ultimately spoke on the substantive matters. The Court concluded that Melendez did not unequivocally invoke his right to remain silent and that his deferrals were tactical rather than an invocation of his rights. Therefore, the prosecutor's comments did not violate Melendez's due process rights. The Arizona Supreme Court affirmed Melendez's convictions and sentences and vacated the Court of Appeals' opinion. View "STATE OF ARIZONA v MELENDEZ" on Justia Law

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