Justia Arizona Supreme Court Opinion Summaries

In this matter concerning vicarious disqualification of a prosecutor's office, the Supreme Court held that a trial court has broad discretion to vicariously disqualify a prosecutor's office based on an appearance of impropriety.Darren Goldin was indicted for first-degree murder. Goldin sought to disqualify the entire Tuscon branch of the Attorney General's office based on ethical violations committed by Richard Wintory, the assistant attorney general. Wintory was removed from the case. Goldin accepted a plea agreement, the plea was revoked, and charges were reinstated after Goldin prevailed on an ineffective assistance of counsel claim. Upon his return to the trial court, Golden again attempted to vicariously disqualify the Tuscon office. The superior court granted the motion based on the appearance of impropriety and the importance of Defendant's constitutional right to counsel. The court of appeals overturned the superior court's disqualification order. The Supreme Court vacated the court of appeals' opinion, holding that, where actual misconduct may have tainted the proceeding, the trial court did not abuse its discretion in disqualifying the Tucson office. View "State v. Honorable Goldin" on Justia Law

The Supreme Court vacated the order of the trial court declining to exercise its discretion to deny a sexually violent person (SVP) screening when the State requested one under Ariz. Rev. Stat. 13-4518(A), holding that remand was required for the trial court to decide whether a screening should occur.Defendant was charged with one count of sexual conduct with a minor. Thereafter, the trial court found Defendant not competent and not restorable. The State requested an SVP screening, arguing that the procedure was warranted under the circumstances. The trial court ordered the screening, concluding that the State was entitled to a screening because the State made a prima facie showing that section 13-4518(A)'s requirements were met. The Supreme Court vacated the order, holding (1) under section 13-4518, trial courts have discretion to deny the State's SVP screening request; and (2) the trial court in this case erred by not exercising that discretion. View "Garcia v. Honorable Butler" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendant's conviction and sentences and remanding for a new trial, holding that the trial court did not adequately confirm that Defendant waived his right to conflict-free counsel.Defendant and his co-defendant were charged with conspiracy, possession and transportation of marijuana for sale, and unlawful possession of drug paraphernalia. At Defendant's arraignment, the prosecutor noted his concern about one attorney representing both codefendants were they were competing defenses. Defense counsel dismissed the concerns because the codefendants had signed a waiver of potential conflict after being advised of their rights. The jury ultimately convicted both defendants on all counts. The Supreme Court vacated the convictions, holding that the joint representation presented an actual conflict that violated Defendant's Sixth Amendment right to conflict-free representation. The Supreme Court affirmed, holding that Defendant did not knowingly and intelligently waive the right to conflict-free counsel. View "State v. Duffy" on Justia Law

The Supreme Court reversed the judgment of the post-conviction court granting Defendant post-conviction relief (PCR) on the ground that counsel's ineffectiveness challenged Defendant, holding that Defendant's lawyers were not deficient by failing to challenge a challenged jury instruction.Defendant was convicted of five counts of first-degree murder and other charges. The jury returned death sentence verdicts on each murder count. Defendant later brought his petition for PCR, claiming that his counsel were constitutionally ineffective for failing to object to the Revised Arizona Jury Instruction's (RAJI) definition of "significantly impaired." The post-conviction court concluded that the RAJI had misstated the law by using the word "prevented" and that both trial and appellate counsel were constitutionally ineffective for failing to challenge the instruction. The Supreme Court reversed, holding that even if Defendant's counsel were deficient for failing to challenge the RAJI, Defendant's defense was not prejudiced. View "State v. Miller" on Justia Law

The Supreme Court held that Ariz. Rev. Stat. 28-672(G), which limits the amount of restitution that can be awarded to a victim for an unconstitutional limitation on the right to receive restitution or a valid legislative enactment, is unconstitutional and void.The Victims' Bill of Rights (VBR), Ariz. Const. art. II, 2.1, guarantees a victim's right to receive prompt restitution for loss or injury caused by a defendant's criminal conduct and authorizes the legislature to enact laws to define, implement, preserve and protect victims' rights. At issue was whether section 28-672(G), which limits the restitution that can be awarded to a victim for loss resulting from a violation of specified traffic offenses, was unconstitutional, either as a limitation on the right to receive restitution or a valid legislative enactment. The Supreme Court held (1) the constitutional right under the VBR to receive restitution is a right to receive the full amount of economic loss or injury caused by a defendant's criminal conduct; and (2) therefore, section 28-672(G)'s limitation on a restitution award is an unconstitutional limitation on the right to receive prompt restitution, as guaranteed by the VBR. View "State v. Patel" on Justia Law

In this special action challenging the trial court's ruling that Defendant's due process rights required disclosure of the victim's privileged records for in-camera review, the Supreme Court held that the trial court did not err in ordering in-camera review.Defendant was charged with second-degree murder for killing M.S., his girlfriend. Before trial, Defendant moved to compel Magellan Hospital to disclose for in-camera review M.S.'s privileged mental health records. The trial court ruled that Defendant's due process rights required dislosure of the privileged records for in-camera review. M.S.'s siblings filed a special action under Arizona's Victims' Bill of Rights challenging the ruling. The court of appeals granted relief, concluding that there was not a substantial probability that the records contained information critical to Defendant's justification defense. The Supreme Court vacated the court of appeals' opinion and affirmed the trial court's judgment, holding that a record of M.S.'s purported mental illness would be material to Defendant's justification defense. View "R.S. v. Honorable Peter A. Thompson" on Justia Law

The Supreme Court vacated the decisions of the court of appeals affirming Defendants' convictions of aggravated assault, holding that the prosecutor's misstatement of the reasonable-doubt standard during a rebuttal argument constituted fundamental error and was prejudicial.Specifically, the Supreme Court held (1) the prosecutor’s material misstatement of the reasonable-doubt standard was both fundamental error and prejudicial error because it went to the foundation of the case and deprived Defendants of an "essential right" necessary to rebut the State's case; and (2) neither the jury instructions nor the presumption that the jury followed the court's instructions cured the prejudice. View "State v. Murray" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing Defendant's conviction of sexual assault, holding that the court of appeals improperly reversed the conviction on the ground that DNA evidence was improperly admitted.On appeal, the court of appeals held that the "minimal probative value" of the DNA evidence offered during trial was substantially outweighed by a danger of unfair prejudice and confusion and therefore was inadmissible under Ariz. R. Crim. P. 403. The court determined that the error was not harmless and reversed Defendant's conviction. The Supreme Court vacated the decision, holding that the evidence was neither unfairly prejudicial to Defendant nor confusing to the jury. The Court remanded this case to the court of appeals to consider an unresolved issue. View "State v. Gomez" on Justia Law

The Supreme Court affirmed Defendant's convictions, holding that neither the United States nor the Arizona Constitution requires a search warrant or court order for a law enforcement officer to obtain either a user's Internet Protocol (IP) address or subscriber information the user voluntarily provides to an Internet Service Provider (ISP) as a condition or attribute of service.Defendant was indicted on twenty counts of sexual exploitation of a minor under fifteen years of age. Defendant filed a motion to suppress on the grounds that the United States Fourth Amendment and Ariz. Const. art. II, 8 required a warrant or court order to obtain his IP address and ISP subscriber information. The motion was denied, and a jury convicted Defendant on all counts. The court of appeals affirmed. The Supreme Court affirmed, holding that the State lawfully obtained the challenged information with a valid federal administrative subpoena because neither the Fourth Amendment nor article 2, section 8 of the Arizona Constitution requires law enforcement officials to secure a search warrant or court order to obtain IP addresses or subscriber information voluntarily provided to ISPs as a condition or attribute of service. View "State v. Mixton" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentences for first-degree murder and child abuse, holding that no prejudicial error occurred during the trial proceedings.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress; (2) the trial court did not violate the Due Process Clause of the Fourteenth Amendment by admitting a pretrial identification of Defendant; (3) the trial court did not err in denying Defendant's Batson challenges to the State's peremptory strikes of two jurors; (4) the trial court did not err by admitting a video demonstrating the location and movement of Defendant's and the victim's cellphones on the day of the murder; (5) the trial court did not err by restricting Defendant's cross-examination of the State's former case agent; (6) the trial court did not commit fundamental error by failing to reinstruct the jury at the close of the aggravation stage; (7) substantial evidence supported the jury's finding that Defendant killed the victim for pecuniary gain; (8) the jury was properly instructed; (9) the State did not engage in prosecutorial error; and (10) the jury did not abuse its discretion in sentencing Defendant to death. View "State v. Smith" on Justia Law