Justia Arizona Supreme Court Opinion Summaries

Defendant’s rights under the Fourth Amendment to the United States Constitution and article 2, section 8 of the Arizona Constitution were not violated when law enforcement officers followed Defendant’s vehicle onto a private driveway to complete a traffic stop that began on a public road.Defendant was found guilty of possession of marijuana, possession of drug paraphernalia, and transporting methamphetamine for sale. Defendant appealed the trial court’s denial of his motion to suppress evidence seized from him and his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the Constitution does not protect a driver that declines to stop on a public road and retreats onto private property; and (2) the officers’ actions in this case comported with Fourth Amendment standards because Defendant impliedly consented to the location of the stop where he led the officers in his vehicle. View "State v. Hernandez" on Justia Law

An employer who used asbestos materials in its workplace before 1970 has no duty to protect the public from so-called secondary asbestos exposure, which is off-site contact with employees who may have been carrying asbestos fibers on their work clothes.Plaintiff sued Reynolds Metal Company and others, alleging that the defendants negligently caused Ernest Quiroz’s death. Specifically, Plaintiffs alleged that when Quiroz’s father was working at Reynolds’ plant, his clothes were contaminated with asbestos fibers and that Quiroz was exposed to the asbestos fibers, eventually causing Quiroz’s mesothelioma. The superior court granted summary judgment for Reynolds. The Supreme Court affirmed, holding (1) Reynolds did not owe a duty to protect the decedent from exposure to take-home asbestos where no special relationship existed between Reynolds and the decedent, and no duty existed based on public policy; and (2) this Court rejects the duty framework contained in the Restatement (Third) of Torts: Liability for Physical and Emotional Harm, and therefore, no duty existed on that basis. View "Quiroz v. Alcoa Inc." on Justia Law

On its face, Ariz. Const. art. II, 22(A)(2), the so-called On-Release provision, satisfies heightened scrutiny under the Due Process Clause of the Fourteenth Amendment.The On-Release provision precludes bail for felony offenses committed when the person charged is already admitted to bail on a separate felony charge and where “the proof is evident or the presumption great” as to the present charge. Defendant was arrested and held without bail pursuant to the On-Release provision. Defendant moved to modify his release conditions, arguing that the On-Release provision was facially invalid because it deprived him of constitutional right to a pre-detention individualized determination of future dangerousness. The superior court denied the motion. The Supreme Court upheld the constitutionality of the On-Release provision and affirmed the superior court’s order denying Defendant bail, holding that the On-Release provision meets constitutional standards. View "Moreno v. Honorable Nicole Brickner" on Justia Law

Students granted deferred removal action by the United States Department of Homeland Security (DHS) under its Deferred Action for Childhood Arrivals (DACA) policy are not eligible for in-state college tuition in Arizona.In 2013, the Arizona Attorney General filed this action seeking a determination that the Maricopa County Community College District Board’s (MCCCD) policy of accepting employment authorization documents (EADs) issued to DACA recipients by the DHS as evidence of residency for students to receive in-state tuition violated Arizona law. The Attorney General also sought an injunction prohibiting MCCCD from allowing DACA recipients to obtain the in-state tuition rates. Two DACA-recipient MCCCD students who receive in-state tuition intervened. The trial court granted summary judgment to MCCCD and the students, concluding that DACA recipients are “lawfully present” for purposes of eligibility for in-state tuition and are therefore eligible for in-state tuition benefits. The Supreme Court disagreed, holding that DACA recipients are not “lawfully present” for purposes of 8 U.S.C. 1623(a), which governs in-state tuition benefits, and therefore, DACA recipients are not eligible for in-state tuition. View "State ex rel. Attorney General v. Maricopa County Community College District Board" on Justia Law

Students granted deferred removal action by the United States Department of Homeland Security (DHS) under its Deferred Action for Childhood Arrivals (DACA) policy are not eligible for in-state college tuition in Arizona.In 2013, the Arizona Attorney General filed this action seeking a determination that the Maricopa County Community College District Board’s (MCCCD) policy of accepting employment authorization documents (EADs) issued to DACA recipients by the DHS as evidence of residency for students to receive in-state tuition violated Arizona law. The Attorney General also sought an injunction prohibiting MCCCD from allowing DACA recipients to obtain the in-state tuition rates. Two DACA-recipient MCCCD students who receive in-state tuition intervened. The trial court granted summary judgment to MCCCD and the students, concluding that DACA recipients are “lawfully present” for purposes of eligibility for in-state tuition and are therefore eligible for in-state tuition benefits. The Supreme Court disagreed, holding that DACA recipients are not “lawfully present” for purposes of 8 U.S.C. 1623(a), which governs in-state tuition benefits, and therefore, DACA recipients are not eligible for in-state tuition. View "State ex rel. Attorney General v. Maricopa County Community College District Board" on Justia Law

A defendant need not submit additional evidence outside the existing record to establish a “meritorious defense” in a motion to set aside a default judgment under Ariz. R. Civ. P. 60(c) (now 60(b)), and a trial court has broad discretion to determine whether a matter should be decided on the merits.In the instant case, after a hearing at which Plaintiff presented evidence and Defendants failed to appear, the trial court entered a default judgment. Defendants filed a Rule 60(c) motion to vacate the damage award. The trial court granted the motion on the grounds that the record suggested that the judgment amount was excessive. The court of appeals reversed and reinstated the default damages judgment, concluding that Defendants had no presented a “meritorious defense” to support the motion. The Supreme Court vacated the court of appeals’ decision and affirmed the trial court’s order, holding (1) evidence outside the extant record is unnecessary to establish the meritorious defense supporting the motion to vacate; and (2) although a possibly excessive judgment does not automatically entitle a defendant to vacate a default judgment, the trial court in this case acted within its discretion. View "Gonzalez v. Nguyen" on Justia Law

Under Tison v. Arizona, 481 U.S. 137, 158 (1987), in determining if a defendant acted with “reckless indifference to human life” while he was a major participant in a felony, thus making him eligible for the death penalty, the fact-finder may consider evidence of the defendant’s diminished capacity.The postconviction relief (PCR) court in this case granted Defendant relief by commuting his death sentence to a life sentence. The PCR court ruled (1) Defendant was ineligible for the death penalty under Tison because reasonable doubt existed whether he acted with the requisite reckless mental state; and (2) even if Defendant were death-eligible under Tison, he would be entitled to resentencing because he sufficiently demonstrated that the sentencing court would not have imposed the death penalty had it known of his mental health deficiencies. The Supreme Court affirmed the PCR court’s ruling that Defendant was ineligible for the death penalty under Tison, holding that the PCR court did not err by admitting diminished-capacity and voluntary-intoxication evidence in the Tison inquiry. View "State v. Miles" on Justia Law

Pursuant to Ariz. R. Evid. 609(a)(2), evidence of a shoplifting conviction is admissible to impeach a witness only when the court can readily determine that the conviction turned on proof of a dishonest act or false statement.During Defendant’s criminal trial, the prosecution called Witness to testify. Defendant told the court that he intended to impeach Witness with a 2015 misdemeanor shoplifting conviction. The trial court refused to admit the impeachment evidence. The court of appeals affirmed, holding that shoplifting is not categorically a “dishonest act or false statement” for purposes of Rule 609(a)(2). The Supreme Court affirmed, holding that a conviction for shoplifting is not automatically admissible under Rule 609(a)(2) because the crime does not necessarily require the prosecution to prove “a dishonest act or false statement” within the meaning of Rule 609(a)(2). View "State v. Winegardner" on Justia Law

The Arizona Department of Revenue (ADOR) is not authorized to value solar panels owned by SolarCity Corporation and Sunrun, Inc. (collectively, Taxpayers) and leased to residential and commercial property owners.For tax year 2015, ADOR notified Taxpayers that their panels had been assigned full cash values and that taxes would be assessed. Taxpayers sought a declaratory judgment that the panels were considered to have no value under Ariz. Rev. Stat. 42-11054(C)(2) and were not subject to valuation. The tax court ruled that the panels were “general property” that must be valued by county assessors pursuant to section 42-13051(A) and that the county assessors cannot assign a zero value because applying section 42-11054(c)(2)’s zero value provision to the panels would violate the Exemptions Clause and the Uniformity Clause of the Arizona Constitution. The Supreme Court affirmed the tax court’s judgment to the extent it concluded that ADOR lacked statutory authority to value Taxpayers’ leased solar panels but reversed the remainder of the judgment and remanded for a determination as to whether section 42-13054 authorizes county assessors to value the solar panels and, if so, whether section 42-11054(C)(2) requires a zero valuation. If section 42-11054(C)(2) applies, the tax could should determine whether that provision violates the Exemptions Clause or Uniformity Clause. View "SolarCity Corp. v. Arizona Department of Revenue" on Justia Law

The Arizona Department of Revenue (ADOR) is not authorized to value solar panels owned by SolarCity Corporation and Sunrun, Inc. (collectively, Taxpayers) and leased to residential and commercial property owners.For tax year 2015, ADOR notified Taxpayers that their panels had been assigned full cash values and that taxes would be assessed. Taxpayers sought a declaratory judgment that the panels were considered to have no value under Ariz. Rev. Stat. 42-11054(C)(2) and were not subject to valuation. The tax court ruled that the panels were “general property” that must be valued by county assessors pursuant to section 42-13051(A) and that the county assessors cannot assign a zero value because applying section 42-11054(c)(2)’s zero value provision to the panels would violate the Exemptions Clause and the Uniformity Clause of the Arizona Constitution. The Supreme Court affirmed the tax court’s judgment to the extent it concluded that ADOR lacked statutory authority to value Taxpayers’ leased solar panels but reversed the remainder of the judgment and remanded for a determination as to whether section 42-13054 authorizes county assessors to value the solar panels and, if so, whether section 42-11054(C)(2) requires a zero valuation. If section 42-11054(C)(2) applies, the tax could should determine whether that provision violates the Exemptions Clause or Uniformity Clause. View "SolarCity Corp. v. Arizona Department of Revenue" on Justia Law