Justia Arizona Supreme Court Opinion Summaries

Arizona Water Company (AWC), a utility company, sought a rate increase and proposed a step-increase mechanism that would allow the Arizona Corporation Commission to adjust rates between full rate cases. The rate increase mechanism, called the system improvements benefit (SIB), would allow AWC to petition for a rate increase between rate cases to help AWC recoup the cost of newly-completed infrastructure projects. The Commission approved the SIB mechanism with some modifications. The court of appeals vacated the Commission’s approval of the SIB mechanism, concluding that the SIB mechanism did not comply with the state Constitution’s mandate that “the Commission determine a public service corporation’s fair value when setting rates[.]” The Supreme Court vacated the court of appeals’ opinion and affirmed the Commission’s orders approving the SIB mechanism, holding that the SIB mechanism complied with the Constitution’s mandate that the Commission determine the fair value of a utility’s property when setting rates. View "Residential Util. Consumer Office v. Arizona Corp. Comm’n" on Justia Law

When A.C. was born, Mother signed an affidavit of paternity falsely stating that A.C.’s father was unknown. Mother also signed a consent to adoption in favor of Petitioners. When Petitioners found no notice of claim of paternity associated with A.C., Petitioners filed a petition to adopt A.C. Meanwhile, having learned of the child’s birth, Father filed a paternity action. Unaware of the pending paternity action, the juvenile court granted A.C.’s adoption. Petitioners subsequently moved to dismiss the paternity case, and Father moved to set aside the adoption. Even though Father never filed a notice of claim of paternity with the putative fathers registry as statutorily required, the juvenile court set aside the adoption. The court of appeals affirmed. The Supreme Court affirmed, holding that because Father timely filed and served his paternity action, he preserved his right to establish paternity despite his failure strictly to comply with the putative father registration requirement. View "David C. v. Alexis S." on Justia Law

Police officers detained Defendant, who was sitting on a curb outside a vacant building, and questioned him about a suspected burglary. Defendant admitted to the burglary and was arrested. Before his trial, Defendant moved to suppress his statements to the police because they were not preceded by the warnings required by Miranda v. Arizona. The trial court denied the motion, concluding that when Defendant was questioned he was not in custody for Miranda purposes. The Supreme Court affirmed, holding that Defendant’s statements were admissible because he was not in custody for Miranda purposes when he made them. View "State v. Maciel" on Justia Law

A car driven by Courtney Cramer rear-ended a vehicle in which Tammy Munguia was a passenger. The next year, Munguia had surgery on her back to treat her persistent low back pain that resulted from the accident. The surgery did not cure Munguia’s symptoms and may have exacerbated her condition. Munguia subsequently filed a personal injury action against Cramer. Cramer filed a notice naming the surgeon as a nonparty at fault. The trial court granted Munguia’s motion to strike, concluding that, under the common law “original tortfeasor rule” (OTR), Cramer, as the original tortfeasor, was liable for the foreseeable risks arising from her tort, including subsequent medical negligence. The Supreme Court reversed, holding (1) the OTR does not preclude a defendant from alleging, or the trier of fact from considering, fault of a nonparty physician who treated the plaintiff for injuries allegedly sustained from the defendant’s tort; and (2) under the OTR, an individual who negligently causes an injury that reasonably necessitates medical treatment may also be liable for any enhanced harm proximately resulting from the individual’s negligence, including subsequent injury and related damages negligently but foreseeably caused by a medical provider. View "Cramer v. Hon. Starr" on Justia Law

Based on the odor of marijuana emanating from a storage warehouse, police officers obtained a warrant to search a unit in the warehouse. In the ensuing search, the officers seized marijuana growing equipment and hundreds of marijuana plants. The trial court denied Defendant’s motion to suppress, concluding that the passage of the Arizona Medical Marijuana Act (AMMA) did not impact the determination that the odor of marijuana suffices to establish probable cause of issuance of a search warrant. The court of appeals reversed, holding that after the adoption of AMMA, the scent of marijuana, alone, is insufficient evidence of criminal activity to supply probable cause. The Supreme Court vacated the court of appeals’ opinion and affirmed the trial court’s ruling denying the motion to suppress, holding (1) the odor of marijuana emanating from inside a vehicle suffices to establish probable cause unless other facts would cause a reasonable person to believe the marijuana use or possession is authorized by AMMA; and (2) under the totality of the circumstances of this case, the odor of marijuana established probable cause. View "State v. Sisco" on Justia Law

Police officers stopped Defendant’s vehicle for unlawful window tinting. Upon approaching the vehicle and speaking with Defendant, the officers noticed an odor of burnt marijuana emanating from inside the vehicle. The officers searched the car and found a small amount of unburnt marijuana. Defendant was arrested and charged with possession or use of marijuana. Defendant filed a motion to suppress arguing that, after passage of the Arizona Medical Marijuana Act, the odor of marijuana coming from a vehicle does not alone provide probable cause. The trial court denied the motion and then found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that, in the instant case, the odor of marijuana sufficed to establish probable cause, and therefore, the search was authorized by the automobile exception to the warrant requirement. View "State v. Cheatham" on Justia Law

After a jury trial, Defendant was convicted of nine counts of first degree murder, among other crimes. The trial court imposed nine death sentences for the murders. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) the trial court did not err in denying Defendant’s motion to suppress evidence seized during a search of his home; (2) the trial court did not unconstitutionally deny Defendant the opportunity to observe or participate in the State’s DNA testing procedures that consumed certain DNA samples; (3) the trial court did not fundamentally err by ending Defendant’s motion to sever and by permitting joinder of all the counts in the indictment; (4) the trial court did not deprive Defendant of his constitutional right to counsel; (5) the trial court did not prejudicially err in its evidentiary rulings; (6) the evidence was sufficient to support the convictions and the jury’s findings that Defendant committed the murders in an especially cruel manner; (7) although the State made some improper remarks during the State’s opening arguments, they did not deprive Defendant of a fair trial; (8) Defendant’s waiver of his right to present mitigation was voluntary, knowing, and informed; and (9) the jury did not abuse its discretion in finding death sentences appropriate for the murders. View "Arizona v. Goudeau" on Justia Law

After Defendant resisted, two police officers subdued and handcuffed him. The resistance and arrest formed one uninterrupted course of conduct. Defendant was indicted on two counts of resisting arrest under Ariz. Rev. Stat. 13—2508 - one for each officer resisted. The trial court sentenced Defendant to concurrent rather than consecutive terms of imprisonment. The court of appeals vacated one of Defendant’s resisting arrest convictions, concluding that the second conviction arose from the same offense and violated the constitutional prohibition against double jeopardy. The Supreme Court vacated the opinion of the court of appeals, vacated Defendant’s second conviction for resisting arrest, and affirmed the remaining convictions, holding that the legislature did not intend, and the Double Jeopardy Clause does not allow, multiple convictions under section 13-2508 for a single, continuous act of resisting arrest. View "State v. Jurden" on Justia Law

An undercover police officer approached Gray at a bus stop and, in a secretly-recorded conversation, asked if Gray could help him get some crack cocaine. Gray agreed to obtain 20 dollars’ worth of cocaine for a 10-dollar fee. The officer drove with Gray to an apartment complex and gave him 20 dollars; Gray left the car and returned 10 minutes later with the cocaine. The officer gave him the fee. Gray was arrested and charged with sale of narcotics. Gray requested a jury instruction on the entrapment defense, A.R.S. 13-206, which requires a defendant to “admit by [his] testimony or other evidence the substantial elements of the offense charged.” Concluding that Gray had not admitted these elements, the trial court refused. The jury found Gray guilty and the trial court sentenced him to 9.25 years in prison. The court of appeals and Arizona Supreme Court affirmed, rejecting Gray’s argument that his recorded statements were “other evidence” sufficient to show that he affirmatively admitted the substantial elements of the charged offense. A defendant cannot invoke the affirmative defense merely by declining to challenge the state’s evidence, even when it includes incriminating statements made by the defendant to an undercover officer. View "Arizona v. Gray" on Justia Law

After a jury trial, Defendant was found guilty on sixty-seven counts, including nine counts of first-degree murder. The jury returned death verdicts on all nine murder charges. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress; (2) any error in the denial of Defendant’s request to observe or participate in the State’s DNA testing procedures that consumed certain DNA samples was harmless; (3) the trial court did not err by denying Defendant’s motion to sever; (4) Defendant was not deprived of his constitutional right to counsel; (5) Defendant was not deprived of a fundamentally fair trial; (6) the trial court did not abuse its discretion in admitting into evidence other-act evidence, pretrial and in-court identifications, firearms expert testimony, and an autopsy photograph; (7) the trial court did not violate Defendant’s right to present a complete defense; (8) although the prosecutor made some improper remarks during trial, they did not deprive Defendant of a fair trial; (9) the trial court did not prejudicially err during the penalty phase; and (10) the jury did not abuse its discretion in finding death sentences appropriate for each of the nine murders. View "State v. Goudeau" on Justia Law