Justia Arizona Supreme Court Opinion Summaries

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

In 1993, Defendant, who was seventeen years old at the time, pleaded guilty to first-degree murder and other charges. Defendant was sentenced to life in prison. Defendant later filed a petition for post-conviction relief pursuant to Ariz. R. Crim. P. 32, claiming that recent scientific findings concerning juvenile psychology and neurology were newly discovered material facts that entitled him to post-conviction relief. The trial court dismissed the petition. The Supreme Court affirmed, holding that Defendant failed to present a colorable claim because the advancements in juvenile psychology and neurology offered by Defendant merely supplement then-existing knowledge of juvenile behavior that was considered at the time of Defendant’s sentencing. View "State v. Amaral" on Justia Law

After a second jury trial, Defendant was convicted of second degree murder. The State’s evidence supporting the conviction included testimony by a firearms examiner that a certain pistol had fired six shell casings found at the murder scene. The court of appeals affirmed, concluding that the trial court did not abuse its discretion in precluding Defendant from offering expert testimony that firearms examiners use subjective rather than scientifically rigorous methods in drawing conclusions from indentations on shell casings. The Supreme Court vacated the judgment of the trial court in part and remanded, holding that the trial court erred in excluding the expert testimony where Defendant’s expert witness was qualified and his testimony would have been helpful to the jury in understanding the evidence. View "State v. Romero" on Justia Law

In this capital case, Defendant was indicted on two counts of first degree murder. Defendant indicated that he would accept a plea offer to natural life it were offered to him, but the State did not extend a plea offer. Defendant later filed a motion in limine seeking permission to introduce evidence of his willingness to accept a natural life plea offer at the penalty phase of his trial if he is convicted and becomes eligible for the death penalty. The trial court denied the motion, concluding that Defendant’s proposition did not evidence a true acceptance of responsibility for his actions. The Supreme Court vacated the order denying Defendant’s motion to permit introduction of evidence of his pretrial offer to plead guilty, holding that a capital defendant’s pretrial offer to plead guilty in exchange for a natural life sentence is admissible to demonstrate the defendant’s acceptance of responsibility for the murder, a non-statutory circumstance. View "Busso-Estopellan v. Hon. Rosa Morz" 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

Petitioners were each charged with two counts of driving under the influence (DUI). Count two alleged a violation of Ariz. Rev. Stat. 28-1381(A)(3), which prohibits driving a vehicle while there is cannabis (marijuana) or its metabolite in the defendant’s body. Both petitioners were medical marijuana cardholders. Petitioners were each convicted. At issue on appeal was whether the Arizona Medical Marijuana Act (AMMA) immunizes a medical marijuana cardholder from DUI prosecution under section 28-1381(A)(3). The Supreme Court affirmed Petitioners’ conviction, holding (1) the AMMA does not shield a medical marijuana cardholder from prosecution under section 28-1381(A)(3); but (2) the AMMA does but does afford an affirmative defense for those patients who can show that the marijuana or its metabolite was in a concentration insufficient to cause impairment. View "Dobson v. Hon. Crane McClennen" 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

After a jury trial, Defendant was found guilty of two counts of first degree murder for murdering his two young sons. The jury sentenced Defendant to death for each murder. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) the trial court did not err by admitting statements Defendant made to police officers at his home; (2) the trial court did not abuse its discretion in admitting other acts evidence under Ariz. R. Evid. 404(b); (3) the trial court erred in excluding some evidence of Defendant’s mental health and prescription drug use, but the error was harmless beyond a reasonable doubt; (4) the trial court erred in giving a jury instruction defining the Ariz. Rev. Stat. 13-751(F)(6) aggravating factor, but the error was harmless; (5) the trial court did not abuse its discretion by precluding testimony of the former warden in the Department of Corrections; (6) the trial court did not err in admitting testimony of Defendant’s former neighbor about the effect of the murders on the neighbor; and (7) the imposition of the death sentence in this case was not an abuse of discretion. View "State v. Leteve" on Justia Law