Justia Arizona Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of second degree murder. Defendant moved for a new trial under Ariz. R. Crim. P. 24.1(c)(1). The trial court granted the motion for a new trial, concluding that the guilty verdict was contrary to the weight of the evidence. After independently examining the evidence, the court of appeals reversed, concluding that the jury properly weighed the evidence and the verdict was not a miscarriage of justice. The Supreme Court affirmed the trial court’s order granting a new trial, holding (1) the court of appeals exceeded the proper scope of deferential appellate review by independently reweighing the evidence rather than determining if substantial evidence supported the trial judge’s ruling; and (2) substantial evidence existed to support the trial court’s determination. View "State v. Fischer" on Justia Law

After a jury trial, Defendant was found guilty of second degree murder. Following the guilty verdict, Defendant moved for a new trial under Ariz. R. Crim. P. 24.1(c)(1). The trial court granted the motion for a new trial, determining that the verdict was contrary to the weight of the evidence. After independently examining the evidence, the court of appeals reversed, concluding that the jury properly weighed the evidence and its verdict was not a miscarriage of justice. The Supreme Court vacated in part the opinion of the court of appeals and affirmed the order granting a new trial, holding (1) the court of appeals exceeded the proper scope of appellate review by independently reweighing the evidence rather than determining if substantial evidence supported the trial judge’s ruling; and (2) substantial evidence existed to support the trial court’s determination. View "State v. Fischer" on Justia Law

Defendant was charged with possession or use of marijuana. At a settlement conference, Defendant agreed to participate in a drug treatment program through the Treatment Assessment Screening Center (TASC) in return for the State deferring the prosecution. Defendant then made a set of statements to TASC regarding his offense. The State later resumed the prosecution because Defendant had failed to attend TASC seminars and had tested positive for alcohol and marijuana while in the TASC program. Defendant moved to suppress the statements he gave to TASC, arguing that they were made during plea discussions and were therefore protected by Ariz. R. Evid. 410(a)(4). The trial court denied the motion. The court then found Defendant guilty. The court of appeals affirmed, concluding that Defendant’s statements were not protected by Rule 410(a)(4). The Supreme Court vacated the opinion of the court of appeals and affirmed Defendant’s conviction, holding that Rule 410(a)(4) does not apply to deferred prosecution agreements and that a knowing waiver of its provisions does not require specifically referencing the rule. View "State v. Gill" on Justia Law

The Arizona State Retirement System (ASRS) operates a defined-benefit plan for state employees and participating political subdivisions. The City of Chandler operated a deferred-compensation plan in which it contributed money for its employees and permitted employees to defer additional amounts, which were held in trust until distributed to employees, generally at age seventy and one-half. Mary Wade and Marla Paddock, City employees, filed a complaint against ASRS and others on behalf of themselves, arguing that City-contributed payments into the deferred-compensation-plan trust constituted “compensation” for the purpose of calculating ASRS contributions and benefits. The trial court entered summary judgment in favor of the City. The court of appeals reversed, concluding that the term “salary” included the City’s regular contributions to the deferred-compensation-plan. The Supreme Court largely affirmed, holding that the City’s contractually required contributions into the deferred-compensation-plan trust for the benefit of its employees formed part of their salary and was “compensation” under Ariz. Rev. Stat. 38-711(7). View "Wade v. Arizona State Retirement System" on Justia Law

Ariz. Rev. Stat. 12-341.01(A) provides that if a party makes a written settlement offer that is rejected, and the final judgment is more favorable to the offering party, that party “is deemed to be the successful party from the date of the offer.” American Power Products (American) and CSK Auto (CSK) entered into a contract that provided that, in the event of an action arising out of the contract, “the prevailing party shall be entitled to recover…reasonable attorneys’ fees.” American later sued CSK for breach of contract. Before trial, CSK served American with an offer of judgment in the amount of $1,000,001. American did not accept the offer and obtained a jury verdict in the amount of $10,733. The trial court concluded that American was the “prevailing party” at trial and awarded American attorney fees. The court of appeals affirmed the fee award. The Supreme Court reversed, holding (1) because the contract did not define “prevailing party” but did incorporate Arizona law to determine the parties’ rights and remedies, the statute applied for the purpose of determining the successful party; and (2) the trial court correctly determined that American was the prevailing party before CSK’s offer of judgment but erred in ruling that American was the prevailing party after CSK’s settlement offer. View "American Power Products Inc. v. CSK Auto, Inc." on Justia Law

After a jury trial, Defendant pleaded guilty to two counts of first degree murder and one count of first degree burglary. The jury sentenced Defendant to death for each murder. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) the trial court properly denied Defendant’s motion alleging that Arizona’s death penalty statute is unconstitutional without holding an evidentiary hearing; (2) the prosecutor’s statements during closing argument at the penalty phase did not constitute fundamental error; (3) the trial court did not abuse its discretion when it revoked Defendant’s self-representation after Defendant refused to proceed with jury selection on the scheduled trial date; (4) the trial court did not err in denying Defendant’s request for new counsel without holding an evidentiary hearing; and (5) Defendant’s death sentence was appropriate. View "State v. Hidalgo" on Justia Law

At issue in this case was the constitutionality of Ariz. Rev. Stat. 28-1321(C), which allows law enforcement officers to make or direct nonconsensual blood draws from unconscious DUI suspects. Defendant was driving an SUV that was involved in a two-vehicle collision in Arizona. Defendant was airlifted to a Nevada hospital for treatment. Without seeking a warrant, a law enforcement officer instructed Department of Public Safety dispatch to request that Las Vegas police officers obtain a blood sample from Defendant. Defendant was unconscious when the blood sample was taken. Defendant was subsequently charged with numerous offenses, including aggravated driving under the extreme influence of intoxicating liquor with a suspended license. Defendant moved to suppress the results of his blood test, arguing that the statute authorizing his blood draw while unconscious violated his Fourth Amendment rights. The trial court denied the motion. The Supreme Court reversed the denial of Defendant’s motion to suppress, holding (1) section 28-1321(C) is unconstitutional as applied to the facts of this case; and (2) under Arizona law, the good-faith exception to the exclusionary rule would not apply in this case. Remanded to the trial court to determine whether Nevada or Arizona law applies and, if it is Nevada law, whether it supports application of the good-faith exception. View "State v. Havatone" on Justia Law

The Arizona Constitution and related laws forbid bail for defendants accused of sexual conduct with a minor under the age of fifteen when the proof is evident or the presumption great that the defendant committed such a crime. Defendant in this case was charged with multiple sexual offenses. Defendant petitioned to be released on bail, but the trial court concluded that the proof was evident and the presumption great that Defendant committed sexual conduct with a minor under the age of fifteen, rendering him ineligible for bail. Defendant challenged the facial constitutionality of Ariz. Rev. Stat. 13-3961(A)(3) and the corresponding provision of the Arizona Constitution, article 2, section 22(A)(1). The trial court denied relief. The court of appeals reversed, ruling that the provisions were unconstitutional because an individualized determination of dangerousness is necessary to withhold bail. The Supreme Court reversed the trial court’s decision and vacated the court of appeals’ opinion, holding that the provisions at issue are unconstitutional on their face because they are not narrowly focused to protect public safety. Remanded. View "Simpson v. Hon. Phemonia Miller" on Justia Law

The United States Court of Appeals for the Ninth Circuit certified certain questions to the Supreme Court regarding what impact, if any, a lender’s full-credit bid made at an Arizona trustee’s sale has on an insurer’s liability under standard form title insurance policies. The policy provisions at issue were (1) Section 2, which provides that coverage continues in force when an insured acquires the property in a foreclosure sale but the amount of coverage is reduced by all payments made; (2) Section 9, which provides that payments of principal or the voluntary satisfaction or release of the mortgage reduce available insurance coverage, except as provided under Section 2(a); and (3) Section 7, which explains how the insurer’s liability is calculated. The Supreme Court answered the certified questions as follows: (1) Section 2 applies when a lender purchases property by full-credit bid at a trustee’s sale; (2) the full-credit bid does not constitute a “payment” under Sections 2 or 9 of the policy; and (3) accordingly, the full-credit bid neither terminates nor reduces coverage under Section 2 or Section 7. View "Equity Income Partners, LP v. Chicago Title Insurance Co." on Justia Law

After a jury trial, Defendant was found guilty of reckless manslaughter. Defendant appealed, arguing that the trial court erred when it denied his motion to suppress an involuntary blood sample taken for medical purposes when medical personnel rendered treatment against Defendant’s will. The court of appeals affirmed. The Supreme Court vacated the court of appeals’ opinion, holding that, to invoke the medical blood draw exception to the warrant requirement set forth in Ariz. Rev. Stat. 28-1388(E), the state must establish that a suspect expressly or impliedly consented to medical treatment or that medical personnel acted when the suspect was incapable of directing his or her own medical treatment. Remanded with directions that the trial court apply the standards set forth in this opinion. View "State v. Nissley" on Justia Law