Justia Arizona Supreme Court Opinion Summaries

For many years, the City of Phoenix has contracted in collective bargaining agreements with police officers to pay officers for certain time spent on behalf of a police union (“release time”) rather than regular police duties. Taxpayers sued the City, allowing that four release time provisions in a 2012 collective bargaining agreement violated the Gift Clause of the Arizona Constitution. The trial court issued a permanent injunction, ruling that the provisions violate the Gift Clause because they lack a public purpose and are not support by adequate consideration. The court of appeals affirmed. The Supreme Court reversed, holding that the challenged release time provisions do not violate the Gift Clause. View "Cheatham v. DiCiccio" on Justia Law

Defendant was charged with necrophilia and two counts of sexual assault. Defendant moved to suppress evidence of a video taken with his cell phone that he left in the victim’s apartment where he was an overnight guest, contending that the warrantless search of his phone was unconstitutional. The trial court granted Defendant’s motion and suppressed of the video and of statements Defendant made to the police about that video, holding that the evidence resulted from an illegal search. The court of appeals reversed, ruling that the warrantless search of the phone was permissible because Defendant did not have a reasonable expectation of privacy in either the victim’s apartment or his cell phone. The Supreme Court reversed, holding (1) Defendant had a reasonable expectation of privacy in his phone; (2) as an overnight guest, Defendant had a legitimate expectation of privacy in the apartment; and (3) no exception to the warrant requirement existed, and therefore, the good-faith exception to the exclusionary rule did not apply. View "State v. Peoples" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and kidnapping and sentenced to death. For reasons unrelated to this appeal, the Supreme Court remanded for a new penalty phase trial on the murder conviction. After a penalty phase retrial, a jury again determined that Defendant should be sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in allowing Defendant to represent himself during the penalty phase on remand; (2) the trial court did not err by permitting Defendant to waive the presentation of mitigation evidence; (3) the trial court’s denial of Defendant’s motion to strike a certain aggravator was not erroneous; (4) the trial court’s response to a jury question during deliberations was not fundamental error; and (5) there was no prosecutorial misconduct. View "State v. Gunches" on Justia Law

Frank Tamburri seeks the Libertarian Party nomination for United States Senator in the 2016 election. Pursuant to A.R.S. 16-314, Tamburri timely filed a nomination petition which included 4,205 signatures. Robert Graham, Chairman of the Arizona Republican Party, filed suit challenging the validity of 2,845 signatures and sought to exclude Tamburri’s name from the Libertarian primary election ballot. On appeal, Tamburri challenges the trial court’s order excluding his name from the Libertarian primary election ballot for the office of United States Senator. Tamburri concedes that he did not collect at least 3,034 signatures from “qualified signers” under A.R.S. 16-321 and -322. As a preliminary matter, the court rejected Tamburri's procedural arguments. The court held that the signature requirements of H.B. 2608 do not severely burden the ability of candidates to exercise their First Amendment rights where Tamburri has failed to show that the increased signature requirements, either facially or as applied to him, would prevent “reasonably diligent” minor party candidates from gaining ballot access. The court concluded that the 0.25 percent signature requirement is rationally related to the state’s legitimate interest in ensuring that candidates who appear on the general election ballot have some significant modicum of support. Accordingly, the court affirmed the trial court’s judgment excluding Tamburri’s name from the primary ballot. View "Graham v. Tamburri" on Justia Law

Medicare Part C, 42 U.S.C. 1395w-21 et seq., permits enrollees to obtain Medicare-covered healthcare services from private healthcare organizations and their third-party contractors. The Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., regulates health plans offered by private employers to employees. At issue is whether continued inpatient treatment by Providers was medically necessary, and therefore compensable, for several MA Plan Members and ERISA Plan Members initially hospitalized for mental health evaluations or treatment. The court held that the administrative appeals process provided under the Medicare Act preempts arbitration of Medicare-related coverage disputes between private healthcare administrators and providers, even though arbitration would otherwise be required by the parties’ contracts and the Federal Arbitration Act (FAA), 9 U.S.C. 1 et seq. In this case, Providers’ coverage claims are inextricably intertwined with claims for Medicare benefits, and they therefore are subject to the Medicare Act. The Act provides mandatory administrative review procedures for these disputes, which preempt arbitration. The court concluded, however, that the court of appeals erred by deciding that whether Aurora’s ERISA-related claims are arbitrable depends on whether Aurora has standing to assert this claim. The court of appeals should decide on remand whether this claim is arbitrable without considering the standing issue or whether any valid defenses to the claim exist. Therefore, the court remanded to the court of appeals to decide whether ERISA similarly preempts arbitration of ERISA-related coverage disputes. View "United Behavioral Health v. Maricopa Integrated Health Sys." on Justia Law

Police officers detained Defendant, who was sitting on a curb outside a vacant building, and questioned him about a suspected burglary. Defendant admitted to the burglary and was arrested. Before his trial, Defendant moved to suppress his statements to the police because they were not preceded by the warnings required by Miranda v. Arizona. The trial court denied the motion, concluding that when Defendant was questioned he was not in custody for Miranda purposes. The Supreme Court affirmed, holding that Defendant’s statements were admissible because he was not in custody for Miranda purposes when he made them. View "State v. Maciel" on Justia Law

Based on the odor of marijuana emanating from a storage warehouse, police officers obtained a warrant to search a unit in the warehouse. In the ensuing search, the officers seized marijuana growing equipment and hundreds of marijuana plants. The trial court denied Defendant’s motion to suppress, concluding that the passage of the Arizona Medical Marijuana Act (AMMA) did not impact the determination that the odor of marijuana suffices to establish probable cause of issuance of a search warrant. The court of appeals reversed, holding that after the adoption of AMMA, the scent of marijuana, alone, is insufficient evidence of criminal activity to supply probable cause. The Supreme Court vacated the court of appeals’ opinion and affirmed the trial court’s ruling denying the motion to suppress, holding (1) the odor of marijuana emanating from inside a vehicle suffices to establish probable cause unless other facts would cause a reasonable person to believe the marijuana use or possession is authorized by AMMA; and (2) under the totality of the circumstances of this case, the odor of marijuana established probable cause. View "State v. Sisco" on Justia Law

Police officers stopped Defendant’s vehicle for unlawful window tinting. Upon approaching the vehicle and speaking with Defendant, the officers noticed an odor of burnt marijuana emanating from inside the vehicle. The officers searched the car and found a small amount of unburnt marijuana. Defendant was arrested and charged with possession or use of marijuana. Defendant filed a motion to suppress arguing that, after passage of the Arizona Medical Marijuana Act, the odor of marijuana coming from a vehicle does not alone provide probable cause. The trial court denied the motion and then found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that, in the instant case, the odor of marijuana sufficed to establish probable cause, and therefore, the search was authorized by the automobile exception to the warrant requirement. View "State v. Cheatham" on Justia Law

After a jury trial, Defendant was convicted of nine counts of first degree murder, among other crimes. The trial court imposed nine death sentences for the murders. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) the trial court did not err in denying Defendant’s motion to suppress evidence seized during a search of his home; (2) the trial court did not unconstitutionally deny Defendant the opportunity to observe or participate in the State’s DNA testing procedures that consumed certain DNA samples; (3) the trial court did not fundamentally err by ending Defendant’s motion to sever and by permitting joinder of all the counts in the indictment; (4) the trial court did not deprive Defendant of his constitutional right to counsel; (5) the trial court did not prejudicially err in its evidentiary rulings; (6) the evidence was sufficient to support the convictions and the jury’s findings that Defendant committed the murders in an especially cruel manner; (7) although the State made some improper remarks during the State’s opening arguments, they did not deprive Defendant of a fair trial; (8) Defendant’s waiver of his right to present mitigation was voluntary, knowing, and informed; and (9) the jury did not abuse its discretion in finding death sentences appropriate for the murders. View "Arizona v. Goudeau" on Justia Law

After Defendant resisted, two police officers subdued and handcuffed him. The resistance and arrest formed one uninterrupted course of conduct. Defendant was indicted on two counts of resisting arrest under Ariz. Rev. Stat. 13—2508 - one for each officer resisted. The trial court sentenced Defendant to concurrent rather than consecutive terms of imprisonment. The court of appeals vacated one of Defendant’s resisting arrest convictions, concluding that the second conviction arose from the same offense and violated the constitutional prohibition against double jeopardy. The Supreme Court vacated the opinion of the court of appeals, vacated Defendant’s second conviction for resisting arrest, and affirmed the remaining convictions, holding that the legislature did not intend, and the Double Jeopardy Clause does not allow, multiple convictions under section 13-2508 for a single, continuous act of resisting arrest. View "State v. Jurden" on Justia Law