Justia Arizona Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty on sixty-seven counts, including nine counts of first-degree murder. The jury returned death verdicts on all nine murder charges. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress; (2) any error in the denial of Defendant’s request to observe or participate in the State’s DNA testing procedures that consumed certain DNA samples was harmless; (3) the trial court did not err by denying Defendant’s motion to sever; (4) Defendant was not deprived of his constitutional right to counsel; (5) Defendant was not deprived of a fundamentally fair trial; (6) the trial court did not abuse its discretion in admitting into evidence other-act evidence, pretrial and in-court identifications, firearms expert testimony, and an autopsy photograph; (7) the trial court did not violate Defendant’s right to present a complete defense; (8) although the prosecutor made some improper remarks during trial, they did not deprive Defendant of a fair trial; (9) the trial court did not prejudicially err during the penalty phase; and (10) the jury did not abuse its discretion in finding death sentences appropriate for each of the nine murders. View "State v. Goudeau" on Justia Law

Patients filed suit to set aside accord and satisfaction agreements and to recover the amounts paid to release liens. Hospitals, health care providers who treated patients injured by third parties, were paid by the Patients' insurer, AHCCCS, which had negotiated reduced rates with the Hospitals. The Hospitals then recorded liens against the Patients pursuant to A.R.S. 33-931 and A.R.S. 36-2903.01(G) for the difference between the amount typically charged for their treatment and the reduced amount paid by AHCCCS. In order to receive their personal injury settlements with the third parties, Patients settled with the Hospitals by paying negotiated amounts to release the liens. At issue is the validity of these accord and satisfaction agreements. The court assumed, without deciding, that Arizona’s lien statutes are preempted by federal law. But, because there was a bona fide dispute about the enforceability of these liens when the Patients and Hospitals entered into settlement agreements to achieve lien releases, the agreements were supported by adequate consideration and addressed a proper subject matter. Therefore, the accord and satisfaction agreements are valid. View "Abbott v. Banner Health Network" on Justia Law

Defendant was arrested on suspicion of driving under the influence of alcohol or drugs (DUI) and taken to a police station, where he was read an “admin per se” form. The form provided that “Arizona law requires you to submit” to breath, blood, or other bodily substance tests chosen by law enforcement. Defendant subsequently submitted to breath and blood tests and was subsequently charged with five counts of aggravated DUI. Defendant moved to suppress the test results, arguing that the warrantless search violated his Fourth Amendment rights because he did not voluntarily consent to the tests. The trial court denied the motion. Based on the parties’ stipulated facts, the court dismissed three counts and convicted Defendant on the remaining counts. The Supreme Court affirmed Defendant’s convictions, holding (1) Defendant’s consent was not freely and voluntarily given in this case; but (2) because the admonition was given in good faith reliance on precedent, exclusion of the test results was not required. View "State v. Valenzuela" on Justia Law

Defendant was arrested for operating a motorized watercraft while under the influence of alcohol or drugs (OUI) and transported to an aid station used by the sheriff’s office. Defendant read an “OUI Admonishment” form, which provided that “Arizona law requires you to submit” to breath, blood, or other bodily substance tests chosen by law enforcement. Defendant agreed to submit to a blood draw and was subsequently charged with two counts of OUI and one count of extreme OUI. Defendant filed a motion to suppress the test results, arguing that the warrantless search violated his Fourth Amendment rights because he did not voluntarily consent to the test. The justice court denied Defendant’s motion to suppress. A jury subsequently found Defendant guilty. The superior court affirmed. The Supreme Court reversed, holding that Defendant did not consent to giving blood samples in this case. Remanded. View "Brown v. Hon. Crane McClennen" on Justia Law

After a jury trial, Appellant was found guilty of ten counts of sexual exploitation of a minor and one count of conspiracy to commit sexual exploitation of a minor. The court of appeals affirmed the convictions and sentences on appeal. Appellant later filed a petition for post-conviction relief alleging ineffective assistance of trial counsel, ineffective assistance of appellate counsel, and juror misconduct. The trial court summarily dismissed Appellant’s petition for post-conviction relief. The Supreme Court affirmed, holding (1) neither Appellant’s trial counsel nor his appellate counsel provided ineffective assistance; and (2) even if Appellant properly raised his juror misconduct claim, he failed to show prejudice. View "State v. Kolmann" on Justia Law

After a jury trial, Defendant was convicted of murder, assault, and kidnapping. The trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) the trial court properly admitted evidence of statements by Defendant’s brother recounting the events preceding the victim’s death; (2) the admission of gang expert testimony was proper; (3) the trial judge did not commit fundamental error by allowing the jury to consider the Ariz. Rev. Stat. 13-751(F)(6) “especially cruel” aggravator under appropriate limiting instructions; and (4) the jury did not abuse its discretion when it declined to grant Defendant leniency. View "State v. Guarino" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, kidnapping, armed robbery, and burglary. The jury returned a death verdict for the murder. The Supreme Court remanded for a new penalty-phase proceeding on the murder conviction. On resentencing, Defendant was again sentenced to death. The Supreme Court affirmed Defendant’s death sentence, holding (1) while the prosecutor engaged in misconduct in certain instances during trial, the improper remarks did not affect the jury’s verdict; (2) the trial court did not commit reversible error when it denied Defendant’s motion to retry the aggravated phase and prohibited him from offering the guilty verdict as an exhibit during the penalty-phase retrial; (3) the trial court did not err in refusing to instruct the jury that Defendant would never be released if sentenced to prison; (4) the trial court did not violate Batson v. Kentucky when it permitted the State to strike five Hispanic jurors over Defendant’s objection; (5) the trial court did not abuse its discretion in refusing to strike a juror that had previously worked at the same hospital as one of the State’s witnesses; and (6) the death sentence was appropriate in this case. View "State v. Lynch" on Justia Law

The defendant in this criminal case moved to suppress the pretrial identification of a police officer that responded to an emergency call. The trial judge denied the motion to suppress without making any findings regarding the procedure’s suggestiveness or the identification’s reliability. On appeal, the State conceded that the one-person show-up identification procedure was inherently suggestive and that the trial court erred in concluding that the officer’s identification was not subject to a due process identification analysis. Relying on the pretrial hearing transcript, the court of appeals concluded that the officer’s identification of Defendant was reliable and therefore admissible. At issue in this case was whether an appellate court may make a reliability determination in the first instance when the trial court has failed to do so. The Supreme Court affirmed, holding (1) an appellate court may make a reliability determination if the trial court record permits an informed analysis; and (2) the court of appeals in this case had a sufficient record from which to analyze the reliability of the officer’s identification of Defendant, and therefore, the court of appeals did not err in conducting a reliability analysis of Defendant’s identification in the first instance on appeal. View "State v. Rojo-Valenzuela" on Justia Law

After a jury trial, Defendant was found guilty of two counts of felony murder and two counts of kidnapping. Defendant was sentenced to death for each murder. The Supreme Court affirmed, holding (1) under the corpus delicti rule, the State met its burden for both kidnapping charges, and therefore, the trial court did not abuse its discretion in admitting incriminating statements Defendant made to a television reporter; (2) the trial court did not commit fundamental error by failing to give an accomplice instruction; (3) the court’s exclusion of certain expert testimony did not violate Defendant’s right to present a defense or to a fair trial; (4) the trial court did not abuse its discretion by refusing to give a Willits instruction; (5) the use of Defendant’s kidnappings convictions, which were the predicate felonies for Defendant’s felony-murder convictions, to aggravate his sentence was not unconstitutional; (6) the prosecutor did not engage in misconduct during closing arguments; (7) any error in the trial court’s admission of victim impact statements was harmless; and (8) the remainder of Defendant’s arguments regarding his convictions and sentences were without merit. View "State v. Carlson" on Justia Law

Law enforcement officers initiated a traffic stop that ultimately led to Defendant’s arrest for possession of marijuana and drug paraphernalia and aggravated driving under the influence. Defendant moved to suppress the evidence on the ground that the officers lacked reasonable suspicion to pull him over. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding that reasonable suspicion under the Fourth Amendment does not require officers to testify about how their observations reduce or eliminate the possibility that the innocent motoring public will be subject to seizures and does not require trial courts to make specific findings on that issue. View "State v. Evans" on Justia Law