Justia Arizona Supreme Court Opinion Summaries

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 held that Ariz. Rev. Stat. 16-204.01 cannot apply to require a city to consolidate local elections with state and national elections if the city's charter provides otherwise.Section 16-204.01 requires political subdivisions to consolidate local elections with state and national elections when voter turnout for local elections significantly decreases. At issue in this case was whether the home rule charter provision barred application of section 16-204.01 to the City of Tuscon, whose charter required electing local officials on non-statewide election dates. The Supreme Court held that section 16-204.01 was unconstitutional as applied to the City charter and therefore could not preempt the City's election-scheduling provision. View "State ex rel. Brnovich v. City of Tucson" on Justia Law

The Supreme Court affirmed the judgment of the trial court disqualifying the "Stop Surprise Billing and Protect Patients Act" ballot initiative (the Initiative) from the November 2020 general election ballot, holding that there were an insufficient number of signatures to qualify for the ballot.On appeal, Appellant argued that signatures gathered by registered circulators may not be disqualified pursuant to Ariz. Rev. Stat. 19-118(E) if the circulators "de-registered" pursuant to the provisions of the Arizona Secretary of State 2019 Election Procedures Manual (2019 EPM) before the signatures are challenged and that subpoenas were not properly served on the circulators. The Supreme Court affirmed, holding (1) by de-registering pursuant to the provisions of the 2019 EPM a registered petition circulator may not evade the statutory requirement in section 19-118(E) that registered circulators subpoenaed in an election challenge appear for trial; and (2) the subpoenas were properly served on the circulators. View "Leach v. Hobbs" 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 held that a plaintiff does not have to allege bad faith or rebut the good faith presumption in his complaint asserting a claim of negligent disclosure of medical information in order to withstand a motion to dismiss based on the immunity provided by Ariz. Rev. Stat. 12-2296.Plaintiff sued Costco, alleging several claims of action based on Costco's public disclosure of an embarrassing medication that Plaintiff twice rejected. Costco filed a motion to dismiss, asserting that Ariz. Rev. Stat. 12-2296 provided immunity and that Plaintiff's claims were preempted by Health Insurance Portability and Accountability Act (HIPAA). The trial court granted the motion. The Supreme Court reversed, holding (1) Plaintiff was not required to anticipate in his complaint Costco's affirmative defense of qualified immunity under section 12-2296 or to rebut the good faith presumption; and (2) Plaintiff permissibly referenced HIPAA to inform the standard of care for his negligence claim. View "Shepherd v. Costco Wholesale Corp." on Justia Law

The Supreme Court set aside the decision of administrative law judge (ALJ) for the Industrial Commission of Arizona (ICA) denying the claim for benefits filed by deputy John France, who developed post-traumatic stress disorder after he shot and killed a man, holding that the administrative law judge erred by failing to apply the standard required by Ariz. Rev. Stat. 23-1043.01(B).Under section 23-1043.01(B), employees may receive compensation for mental injuries if an unexpected, unusual or extraordinary employment-related stress was a substantial contributing cause of the mental injury. An ALJ denied France's claim for benefits, concluding that the shooting incident was not "unusual, unexpected, or extraordinary." The Supreme Court set aside the ICA's decision, holding (1) under section 23-1043.01(b), a work-related mental injury is compensable if the specific event causing the injury was objectively "unexpected, unusual or extraordinary"; (2) under this objective standard, an injury-causing event must be examined from the standpoint of a reasonable employee with the same or similar job duties and training as the claimant; and (3) the ALJ erred by limiting her analysis to whether France's job duties encompassed the possibility of using lethal force in the line of duty and failing to consider whether the shooting incident was unexpected or extraordinary. View "France v. Industrial Commission of Arizona" on Justia Law

The Supreme Court answered a question certified by the United States Court of Appeals for the Ninth Circuit by holding that, under a policy without a contractual duty to defend, the objective reasonableness of an insurer's decision to withhold consent is assessed from the perspective of the insurer, not the insured.National Union Fire Insurance Company of Pittsburgh, PA, which insured Apollo Education Group, Inc.'s directors and officers for liability up to $15 million under a policy that included no duty to defend the insured if sued. A class action suit against Apollo resulted in an agreement to settle. Apollo refused to consent to the settlement but entered into the agreement. Apollo then sued National Union to recover the settlement amount, alleging breach of contract and bad faith. The district court granted summary judgment to National Union. On appeal, the Ninth Circuit certified the question to this Court. The Supreme Court held that an insurer must, in deciding whether to consent to a settlement, give the matter full and fair consideration, but need not approve a settlement simply because the insured believes it is reasonable. View "Apollo Education Group, Inc. v. National Union Fire Insurance Co." on Justia Law

The Supreme Court affirmed the ruling of the trial court finding that Javier Soto, a candidate for the Democratic Party's nomination for the Arizona House of Representatives in Legislative District 3, obtained enough valid signatures to qualify for placement on the primary election ballot, holding that the district court did not err.Specifically, the Supreme Court held (1) signatures dated with a month and day but no year substantially complied with the requirement of a "[d]ate of signing"; (2) signatures that listed the signer's street address but no municipality, state, or zip code substantially complied with the requirement of an "actual residence address"; and (3) the trial court did not err by finding the signatures valid. View "McKenna v. Soto" on Justia Law