Justia Arizona Supreme Court Opinion Summaries

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

In 2000, Arizona voters approved a referendum that statutorily directed the Legislature to annually increase the base level of the revenue control limit for K-12 public school funding. The measure was codified as Ariz. Rev. Stat. 15-901.01. For several years, the Legislature adjusted the base level and transportation support level annually for inflation, but the 2010-11 budget (HB 2008) included an adjusted to the transportation support level only. Subsequent budgets likewise did not include base level adjustments. Several school districts and other parties sued the State Treasurer and State, alleging that HB 2008 amended or repealed a voter-approved law in violation of the Voter Protection Act (VPA). The superior court dismissed the complaint for failing to state a claim, ruling that section 15-901.01 was not mandatory and that voters "cannot require the legislature to enact a law that provides for the appropriation" prescribed in the statute. The court of appeals reversed. The Supreme Court affirmed, holding that no constitutional impediment existed to the electorate's directive, and legislative adjustments to section 15-901.01's funding scheme are limited by the VPA. View "Cave Creek Unified Sch. Dist. v. Ducey" on Justia Law

Four members of the Commission on Appellate Court Appointments filed this special action asking the court to declare H.B. 2600 unconstitutional and to enjoin the Commission from applying the statute. The Arizona Constitution established the Commission and required it to submit "not less than three" nominees to the governor for her appointment to fill an appellate judicial vacancy. H.B. 2600 directed the Commission to submit "the names of at least five persons" to the governor, unless an applicant was rejected by a two-thirds vote of the Commission, in which case it could submit fewer than five names. The court held that H.B. 2600 was unconstitutional because it directly conflicted with Arizona's Constitution. Accordingly, the court enjoined the Commission from applying the statute and awarded reasonable attorney's fees to petitioners upon compliance with Arizona Rule of Civil Appellate Procedure 21. View "Dobson v. State" 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

A jury found Defendant guilty of felony murder and other crimes. Defendant was sentenced to death for the murder and to prison terms on the other convictions. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not err in permitting the State's medical expert to testify; (2) the trial court did not err by denying Defendant's request for an Enmund/Tison jury instruction at the aggravation phase of trial; (3) Defendant's waiver of his right to present mitigation was voluntary, knowing, and informed; and (4) the jury did not abuse its discretion in concluding that the mitigating circumstances were not sufficiently substantial to call for leniency. View "State v. Joseph" on Justia Law

On January 27, 2012, the Yuma County Superior Court disqualified Alejandrina Cabrera under Ariz. Rev. Stat. 38-201(C) from appearing on the ballot as a candidate for the San Luis City Council. Concluding that section 38-201(C)'s language requirement must be read "in the context of the political office at issue," the court found that Cabrera was not sufficiently proficient in English to perform as a city council member for San Luis. The Supreme Court affirmed, holding, in relevant part, that (1) the trial court correctly interpreted section 38-201(C); and (2) the trial court's interpretation of the statute did not unconstitutionally violate Cabrera's right to participate in government. View "Escamilla v. Cuello" on Justia Law