Justia Arizona Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions for multiple counts of first degree murder and sentence of death, holding that no prejudicial error occurred in the proceedings below.After a ten-day trial, a jury found Defendant guilty of the 2012 first degree murders of Penelope Edwards and Troy Dunn under both premeditated and felony murder theories. After the penalty phase of trial, the jury returned death verdicts for both murders. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered during a traffic stop and any fruit of that search; (2) the trial court did not err in the way it conducted voir dire; (3) Defendant's evidentiary challenges were without merit; (4) one instance of prosecutorial error occurred, but the error was not prejudicial; (5) any error during the aggravation phase was harmless; and (6) Defendant's challenges to the death penalty were unavailing. View "State v. Thompson" on Justia Law

The Supreme Court held that four legislative budget reconciliation bills (BRBs) - House Bill (HB) 2898, Senate Bill (SB) 1824, SB 1825, and SB 1819 - violated the Arizona Constitution's title requirement and were therefore void in part and that SB 1819 violated the constitutional single subject rule.Plaintiffs - the Arizona School Boards Association and other organizations and citizens - challenged four of the eight BRBs included in the 2022 budget approved by the legislature and signed by the Governor. The trial court ruled that the challenged sections of all four BRBs violated the title requirement and that the entirety of SB 1819 violated the single subject rule. The Supreme Court affirmed, holding that the trial court did not err in ruling that the noncompliant portions of HB 2898, SB 1824, SB 1825, and SB 1819 were unconstitutional in violation of the title requirement and that SB 1819 was unconstitutional and void in violation of the single subject rule. View "Arizona School Boards Ass'n, Inc. v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court in Plaintiffs' favor on their common law negligence claims and their dram shop liability claim against JAI Dining Services (Phoenix) Inc., holding that the trial court properly submitted to the jury the question of whether JAI was relieved from liability from overserving alcohol.After spending the evening drinking and socializing at a club in Phoenix, Cesar Villanueva, while intoxicated, drove his truck home. Villanueva fell asleep for a short time before he agreed to take a friend home. Villanueva, however, was still intoxicated and struck a vehicle, killing two people. Villanueva was convicted of two counts of manslaughter and was sentenced to life imprisonment. Plaintiffs, the victims' families, sued JAI, which owned the club, alleging negligence-based claims for over serving alcohol to Villanueva. The jury returned a verdict in favor of Plaintiffs. The Supreme Court affirmed, holding that a jury could reasonably have concluded that Villanueva’s act of driving while intoxicated, even after he reached home, was nevertheless foreseeable by someone in the club’s position and not extraordinary in hindsight. View "Torres v. JAI Dining Services" on Justia Law

The Supreme Court affirmed the order of the juvenile court terminating the parent-child relationship of Father to his four children, holding that while the juvenile court misapplied two factors set forth in Michael J. v. Arizona Department of Economic Security, 196 Ariz. 246 (2000), substantial evidence existed to support the termination.After a hearing, the juvenile court found that Father's incarcerative sentence was of sufficient length to deprive the children of a normal home for a period of years and that termination of Father's parental rights was in the children's best interests. The court of appeals affirmed, concluding that the juvenile court did not abuse its discretion in evaluating the Michael J. factors. The Supreme Court affirmed, holding (1) the juvenile court misapplied the first two Michael J. factors; (2) the juvenile court did not abuse its discretion in determining that Father's sentence was of sufficient length to deprive the children of a normal home for a period of years; and (3) reasonable evidence supported the juvenile court's best-interests finding. View "Jessie D. v. Department of Child Safety" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the decision of the Arizona Corporation Commission to consolidate several communities into a single service district, gradually increasing rates for some and lowering them for others to achieve uniform rates, holding that there was no error.The Commission consolidated the monthly wastewater rates paid by five wastewater districts acquired by EPCOR Water Arizona Inc. in 2012. Sun City, one of the wastewater districts, appealed, arguing that the consolidated rate discriminated against residents of Sun City. The court of appeals upheld the Commission's decision. The Supreme Court affirmed, holding that the rates approved by the Commission for the fully consolidated EPCOR district did not violate Ariz. Const. art. XV, 12. View "Sun City Home Owners Ass'n v. Arizona Corp. Commission" on Justia Law

The Supreme Court held in this case that a crime victim has a constitutional and statutory right to be heard on the merits of a defendant's motion for a delayed appeal of a restitution order.Defendant was convicted of second-degree murder. Beth Fay was a victim of Defendant's crime under Arizona law. Defendant and Fay entered into an agreement regarding restitution, and the trial court entered a restitution award according to the agreement. Eight months later, Defendant filed a limited petition for post-conviction relief to contest the award pursuant to Ariz. R. Crim. P. 32.1(f). Fay filed a response, arguing that Defendant was not entitled to a delayed appeal. The trial court struck Fay's response on the ground that Fay lacked standing to be heard on Defendant's limited petition. The court of appeals affirmed. The Supreme Court reversed, holding that Fay had a right to be heard on the question of whether Defendant was entitled to file a delayed appeal. View "Fay v. Honorable Fox" on Justia Law

The Supreme Court held that Arizona's open-meeting and conflict-of-interest laws broadly confer standing based upon a claimant's interest in preserving the values of transparency and accountability that the laws enshrine, not because of a claimant's equitable ownership of tax revenues.The laws at issue in this case grant people affected by either an alleged violation or a public agency's decision standing to enforce their respective requirements. The open-meeting law also provides that legal action taken in violation of the law is null and void unless the public body later takes the proper steps to "ratify" that action. Before the Supreme Court was private claimants' standing to challenge alleged violations of Arizona's public accountability laws and the effect statutory ratification has on a private claimant's open-meeting claim. The Supreme Court vacated the portions of the court of appeals' opinion analyzing the laws' enforcement provisions through the lens of taxpayer standing, holding (1) Ariz. Rev. Stat. 38-431.07(A), and -506(B) grant standing to all who fall within the broader "zone of interests" protected by Arizona's public accountability laws; and (2) ratification under section 38-431.05(B) does not act as a complete cure to an open-meeting violation but merely negates the original action's default nullification. View "Welch v. Cochise Board of Supervisors" on Justia Law

The Supreme Court held that a hospital may not directly recover from a third party the costs of uncompensated medical care provided to patients whose need for treatment the third party allegedly caused because the exclusive right for a hospital to recover from a third-party tortfeasor is through the medical lien statutes.Tuscon Medical Center (TMC) brought this action against CVS Health Corporation and other CVS entities (collectively, CVS) alleging that CVS failed to exercise due care in dispensing opioids into Arizona communities. CVS filed a motion to dismiss, arguing that Arizona's medical lien statutes precluded all of TMC's claims against it. The Supreme Court reversed the trial court's ruling denying CVS's motion to dismiss TMC's negligence claims, holding (1) TMC was barred from pursing a negligence claim against CVS to recover indirect damages and was limited to suing the patient or perfecting and collecting on a statutory lien; and (2) CVS did not owe a duty to TMC under the facts alleged. View "CVS Pharmacy, Inc. v. Honorable Bostwick" on Justia Law

The Supreme Court accepted a question certified to it by the United States Court of Appeals for the Ninth Circuit and answered that Arizona has not consented to damages liability for a state agency's violation of the minimum wage or overtime provisions of the federal Fair Labor Standards Act (FLSA), 29 U.S.C. 206-207.Plaintiff brought this putative claims action complaint asserting that the State violated the FLSA by failing to pay minimum wage and overtime compensation to state-employed in-home caretakers who, like herself, provide around the clock care to beneficiaries of the Arizona Long-Term Care System. The State removed the case to federal district court. The court granted the State's motion to dismiss, thus rejecting Plaintiff's contentions that the State waived its sovereign immunity by removing the case to the federal court and that the State waived its sovereign immunity as a matter of law. The Ninth Circuit then certified its question to the Supreme Court. The Supreme Court answered that the legislature has neither expressly consented nor implied its consent to federal damages liability, and therefore, Arizona has not consented to damages liability for a state agency's violation of the FLSA's minimum wage or overtime provisions. View "Redgrave v. Ducey" on Justia Law

The Supreme Court held that the direct funding provision of Proposition 208 did not fall within the constitutional definition of grants in Ariz. Const. art. IX, 21 (the Education Expenditure Clause) and was therefore unconstitutional to the extent it mandated expanding tax revenues in violation of the Education Expenditure Clause.Proposition 208 was a citizens' initiative passed in 2020 imposing an income tax purchase on high-income Arizona taxpayers to provide direct funding to schools. Petitioners brought this action challenging the constitutionality of the tax and the initiative's characterization of the direct funding as "grants" exempt from the Education Expenditure Clause and seeking to enjoin the collection of that tax pending the resolution of their challenge. The Supreme Court held (1) because Ariz. Rev. Stat. 15-1285 incorrectly characterizes the allocated monies in order to exempt Proposition 208 from the Education Expenditure Clause, it is facially unconstitutional; (2) the remaining non-revenue related provisions of Proposition 208 are not severable; (3) this Court declines to enjoin the imposition of the tax pending further proceedings; and (4) Proposition 208 does not violate the Tax Enactment Clause of the Arizona Constitution, and therefore, the bicameralism, presentment, and supermajority requirements found therein are inapplicable. View "Fann v. State" on Justia Law