Justia Arizona Supreme Court Opinion Summaries

At issue in this case was when “entry” occurs under Ariz. R. Crim. P. 31.3, which requires that a notice of appeal be filed within twenty days after the “entry” of judgment and sentence. After a jury trial, Defendant was convicted of four counts of aggravated DUI. Defendant filed his notice of appeal twenty-one days after his sentencing but only nineteen days after the clerk of court filed the minute entry memorializing Defendant's sentence. The State challenged the notice as untimely. The court of appeals held that the timeliness of Defendant’s appeal could be measured from the date the minute entry was filed. The Supreme Court vacated the opinion of the court of appeals and dismissed the appeal, holding that entry occurs when the sentence is pronounced, and defendants have twenty days from that date to file a notice of appeal. View "State v. Whitman" on Justia Law

In 1998, Arizona voters passed an initiative to create the Citizens Clean Elections Act (“CCEA”), which established public funding for political candidates in statewide and state legislative elections. Under this system, candidates who opt not to receive public funding (“nonparticipating candidates”) cannot accept contributions greater than eighty percent of the campaign contribution limits as specified in Ariz. Rev. Stat. 16-905. In 2013, the legislature passed H.B. 2593, which amended section 16-905 by increasing campaign contribution limits. The Citizens Clean Elections Commission and others ("Commission") asked the superior court to declare H.B. 2593 unconstitutional and to enjoin the Secretary of State from implementing it, alleging that the CCEA fixed campaign contribution limits as they existed in 1998 for nonparticipating candidates. The superior court denied the Commission’s motion for a preliminary injunction. The issue eventually reached the Supreme Court, which held that, rather than fixing contribution limits at eighty percent of the amounts that existed in 1998, the CCEA provides a formula for calculating contribution limits, and therefore, the superior court did not err in its judgment. View "Ariz. Citizens Clean Elections Comm’n v. Hon. Brain" on Justia Law

James Koontz was charged with one count of aggravated assault and a domestic violence offense, and Robert Gill was charged with three counts of theft of a means of transportation. The prosecutor in both cases unilaterally redacted the victims’ birth dates from law enforcement reports disclosed to the defense. In both cases, defense counsel filed motions to compel disclosure, which the trial courts granted. The State subsequently petitioned for special action. The court of appeals consolidated the cases and granted relief to the State. The Supreme Court vacated the court of appeals’ decision and remanded with regard to Gill, as Koontz did not participate in the petition for review, holding that a prosecutor must obtain a court order to authorize redacting victims’ birth dates from law enforcement reports that must be disclosed to defense counsel. View "State ex rel. Montgomery v. Hon. Chavez" on Justia Law

A grand jury indicted Appellant for first degree murder, among other offenses. The grand jury also found probable cause to support three aggravating circumstances to support the imposition of the death penalty. Appellant filed a motion to remand for a new finding of probable cause, arguing that the grand jury was precluded from considering the aggravating circumstances and that the State’s presentation of the issue denied him the opportunity to request a Chronis hearing. The trial court denied the motion. The court of appeals affirmed, concluding that a capital case defendant is not entitled to a Chronis hearing if a grand jury has found that probable cause supports the existence of alleged aggravating circumstances. The Supreme Court vacated the lower courts’ judgments and directed the trial court to grant Appellant’s request and hold a Chronis hearing, holding that the grand jury lacks authority to determine whether probable cause supports the existence of aggravating circumstances alleged in a capital case, and any grand jury findings concerning aggravating circumstances cannot deprive a defendant of a timely requested Chronis hearing. View "Sanchez v. Hon. Ainley" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first degree murder for stabbing his pregnant girlfriend, killing her and the unborn baby. Appellant was sentenced to death. The Supreme Court affirmed Appellant’s convictions and death sentences, holding that the trial court did not (1) err in denying Appellant’s motion to suppress his post-arrest confession; (2) err in striking a juror for cause; (3) err in screening and limiting questions used in a written questionnaire sent to prospective jurors; (4) err in precluding or limiting the testimony of three defense witnesses; (5) commit fundamental error by allowing evidence of statements Appellant made four years before the murders; (6) abuse its discretion in finding that the State’s mental health expert qualified as an expert in intellectual disability and in therefore allowing the expert to testify on the issue of Appellant’s intellectual ability; and (7) violate Appellant’s right to counsel by not declaring a mistrial based on the alleged ineffectiveness of Appellant’s trial attorneys. In addition, the jury did not abuse its discretion in finding aggravating circumstances and in determining that death was the appropriate sentence. View "State v. Naranjo" on Justia Law

In 1985, the Arizona Legislature established the Elected Officials’ Retirement Plan (“Plan”), which provides pension benefits for elected officials, including judges. Ariz. Rev. Stat. 38-818 establishes a formula for calculating pension benefit increased for retired members of the Plan. In 2011, the Legislature enacted S.B. 1609, which modified the formula set forth in section 38-818. Two retired judges, on behalf of themselves and as representatives of a class of retired Plan members and beneficiaries, sued the Plan and its board members, alleging that S.B. 1609 violated Ariz. Const. art. 29, 1(C). The trial court ruled in favor of Plaintiffs, concluding that S.B. 1609 violated Article 29, 1(C)’s prohibition against the diminishment or impairment of public retirement system benefits. The Supreme Court affirmed, holding that because the statute diminished and impaired the Plan’s retired members’ benefits, it violated the Pension Clause of Article 29, 1(C). View "Fields v. Elected Officials’ Ret. Plan" on Justia Law

After a jury trial, Defendant was convicted of two counts of first degree felony murder and six other felonies for offenses committed during a home invasion. The trial court imposed death sentences for the murders and prison sentences totaling seventy-five years for the non-capital counts. The Supreme Court affirmed Defendant’s convictions and sentences but ordered that her sentences for armed robbery and aggravated robbery run concurrently, holding, among other things, that (1) the trial court did not commit reversible error in granting Defendant’s motion for a change of venue based on extensive media coverage of the crimes, deciding its rulings regarding jury selection, and instructing the jury; (2) the prosecutor did not commit misconduct; and (3) the trial court erred in imposing consecutive sentences for robbery and aggravated robbery because these crimes were based on a single act by Defendant. View "State v. Forde" on Justia Law

After a jury trial, Defendant was convicted of five counts of first degree murder, among other charges, and sentenced to death for each murder. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) Defendant was not deprived of his right to a speedy trial; (2) the trial court did not abuse its discretion by consolidating the murder and solicitation of first degree murder charges; (3) the trial court did not err in admitting into evidence certain victims’ recorded statements; (4) the trial court did not err in denying Defendant’s motion for mistrial; (5) the trial court did not err in admitting a forensic firearms expert’s testimony; (6) substantial evidence supported the solicitation convictions; (7) the trial court did not err in its jury instructions; (8) and substantial evidence supported the jury’s findings of aggravating circumstances and the imposition of the death sentences. View "State v. Miller" on Justia Law

After a jury trial, Appellant was convicted of two counts of first degree murder and thirty counts of attempted first degree murder following a shooting spree at a homeowners' association meeting in 2000. Appellant was sentenced to death. The Supreme Court affirmed the convictions and sentences on appeal. In 2010, Appellant filed a petition for post-conviction relief. The petition was pending when Appellant died in 2013. The superior court subsequently dismissed Appellant's post-conviction relief proceeding as well as his indictment and conviction under State v. Griffin, in which the Supreme Court held that when a convicted defendant dies before his direct appeal is decided, the prosecution is abated from the outset, and the conviction is set aside. The Supreme Court vacated the superior court's judgment, holding that the doctrine of abatement ab initio set forth in Griffin does not apply when a defendant dies after his conviction is affirmed but while post-conviction relief proceedings are pending. View "State v. Glassel" on Justia Law

Defendant was charged with four felonies relating to an assault. After Defendant agreed to plead guilty to a lesser charge, he admitted at a change-of-plea hearing that he was an accomplice. Later Defendant denied any involvement. The trial court subsequently rejected the plea agreement. During the trial proceedings, Defendant moved to prevent the State from using statements he made during the change-of-plea hearing. The trial court ruled that the State could impeach Defendant with his statements if he testified inconsistently with them at trial. Defendant did not testify at trial, and the jury found him guilty on all counts. The Supreme Court affirmed, holding (1) the trial court erred in ruling the State could use Defendant's change-of-plea statements to impeach him; but (2) Defendant could not raise the trial court's error on appeal because a defendant must testify to preserve a challenge to a ruling permitting the use of evidence for impeachment. View "State v. Duran" on Justia Law