Justia Constitutional Law Opinion Summaries

The Supreme Court held that legislative amendments to Ariz. Rev. Stat. 13-751(F)(5) enacted in 2019 did not provide a basis for post-conviction relief under Ariz. R. Cim. P. 32.1(a), (c), (g), or (h) for a sentence of death imposed in 1996 because the amendments were prospective only and the death sentence was constitutional.In 1996, Defendant was convicted of first-degree murder - felony and premeditated. The trial court sentenced him to death. In 2020, Defendant filed this successive post-conviction relief (PCR) petition alleging that his death sentence was now unconstitutional as a consequence of 2019 legislative amendments. The superior court granted relief and vacated Defendant's death sentence. The Supreme Court reversed and affirmed Defendant's sentence, holding that the sentence was lawfully imposed and did not violate Defendant's constitutional rights under either the United States or Arizona Constitutions. View "State v. Greene" on Justia Law

The Supreme Court held that certain statements made on air by a radio talk show host about a political figure could not serve as a basis for a defamation action given each statement's content, the overall context, and the protections afforded to core political speech by the First Amendment.Respondent Daniel McCarthy, a "Republican political hopeful," sued James Harris, a radio host on a local station owned by iHeartMedia, Inc. (collectively, Petitioners), alleging that statements made by Harris on his radio show were defamatory. Petitioners filed a motion to dismiss, arguing that the statements were rhetorical hyperbole incapable of being proved false and thus protected by the First Amendment. The trial court denied the motion to dismiss. The Supreme Court reversed, holding that none of the statements at issue were actionable because none of them could be reasonably interpreted as asserting or implying false statements of fact that defamed McCarthy. View "Harris v. Honorable Warner" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction relief (PCR) court determining that Appellant raised a colorable claim for ineffective assistance of trial counsel and ordering him to disclose certain materials, holding that the PCR court did not err in ordering the disclosure of the records.Appellant was found guilty of two counts of first degree murder and sentenced to death. In these PCR proceedings, the PCR court determined that Appellant's ineffective assistance of counsel claim in III(A)-III(E) of the PCR petition was colorable. The court then ordered Appellant to disclose materials associated with trial counsel's interviews of three of Appellant's family members who did not testify during the penalty phase of trial. Appellant filed a petition for special action, claiming that he should not have to disclose the records at issue. The Supreme Court affirmed, holding that there was good cause for the disclosure of materials associated with the interviews under Ariz. R. Crim. P. 32.6(b)(2). View "Naranjo v. Honorable Sukenic" on Justia Law

The Supreme Court held that Ariz. Rev. Stat. 23-1043.01(B), which limits workers' compensation claims for mental illnesses to those that arise from an "unexpected, unusual or extraordinary stress" situation, does not violate Ariz. Const. art. XVIII, 8 or equal protection guarantees under Ariz. Const. art. II, 13.Plaintiff, an officer with the Tucson Police Department, filed an industrial injury claim arising from an incident in June 2018, claiming that it exacerbated his preexisting post-traumatic stress disorder. An administrative law judge found Plaintiff's claims for mental injuries non-compensable because the June 2018 incident was not an "unexpected, unusual or extraordinary stress" situation under section 23-1043.01(B). The court of appeals affirmed the denial of benefits. The Supreme Court affirmed, holding that section 23-1043.01(B) does not unconstitutionally limit recovery for stress-related workplace injuries. View "Matthews v. Industrial Comm'n" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion seeking remand to the grand jury for a redetermination of probable cause pursuant to Ariz. R. Crim. P. 12.9, holding that the trial court did not err in denying Defendant's Rule 12.9 motion.A grand jury indicted Defendant for attempted second degree murder and other crimes. Defendant subsequently filed the motion at issue, arguing that the State withheld clearly exculpatory evidence of a justification defense that it was obligated to present despite the evidence not being requested by the defense. The trial court denied the motion. The Supreme Court reversed, holding (1) the Arizona Constitution guarantees a person under grand jury investigation a due process right to a fair and impartial presentation of clearly exculpatory evidence, and a prosecutor has a duty to present such evidence to a grand jury even in the absence of a specific request; (2) where there is evidence relevant to a justification defense that would deter a grand jury from finding probable cause the prosecutor has an obligation to present such evidence; and (3) the State failed to present clearly exculpatory evidence in this case, denying Defendant a substantial procedural right. View "Willis v. Honorable Bernini" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the superior court dismissing this complaint seeking declaratory and injunctive relief, holding that, for the most part, the doctrines of exhaustion of administrative remedies, ripeness, and standing did not prohibit Plaintiff from proceeding with his lawsuit.Plaintiff was an engineer who designed, tested, and built electronic circuits from consumer products through his consulting firm. At issue in this dispute with the Arizona Board of Technical Registration was whether Plaintiff's work required registration with the Board. Plaintiff brought this action under the Uniform Declaratory Judgments Act, Ariz. Rev. Stat. 12-1831 to -1846, challenging the constitutionality of statutes prohibiting people and firms from engaging in "engineering practices unless registered with the Board." The superior court dismissed the complaint on two bases. The Supreme Court reversed in part, holding (1) three causes of action in Plaintiff's complaint were justiciable, and the superior court erred by dismissing them s nonjusticiable; and (2) the court correctly dismissed the fourth cause of action as unripe. View "Mills v. Arizona Bd. of Technical Registration" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of thirteen felony counts of aggravated harassment, holding that the trial court did not abuse its discretion in accepting Defendant's jury-trial waiver.At issue on appeal was whether, in a case where a criminal defendant's competency has been put at issue, a trial court must make a specific finding of heightened competency before determining that the defendant's waiver of the right to a jury trial is voluntary, knowing, and intelligent. The Supreme Court answered the question in the negative, holding (1) Arizona law does not require a finding of heightened competency for a jury-trial waiver where a defendant's competency has been put at issue; and (2) the trial court did not abuse its discretion in concluding that Defendant had knowingly, voluntarily, and intelligently waived his right to a jury trial. View "State v. Muhammad" on Justia Law

The Supreme Court upheld the decisions of the lower courts in this matter arising from two criminal cases, holding that the Cochise County Superior Court's innominate jury system does not violate the First Amendment.This case arose from two criminal cases that used innominate juries without objection by either party. In both cases, Appellant, a journalist, unsuccessfully sought access to prospective and impaneled jurors' names before and after trial. The court of appeals affirmed. On appeal, Appellant argued that the First Amendment provides a qualified right of public access to jurors' names during voir dire, thus creating a presumption of access that can be overcome only on a case-by-case basis by showing both that a compelling state interest exists in a particular case to shield the names and that denying access is a remedy narrowly tailored to serve that interest. The Supreme Court affirmed, holding that the First Amendment does not provide the press or public with a qualified right to access jurors' names, and the law is facially valid. View "Morgan v. Honorable Dickerson" on Justia Law

On July 18, 2012, Robinson beat, bound, and immolated his nine-months-pregnant girlfriend, S.H., in their apartment, killing her and their unborn child, B.H. He then placed a 9-1-1 call to report a fire. Upon extinguishing the fire, responders discovered S.H.’s partially burned body lying face down on the bedroom floor with her feet and hands bound, wrists handcuffed, mouth and eyes covered with duct tape, and mouth stuffed with cloth. A search of Robinson’s backpack revealed rolls of duct tape, pieces of crumpled duct tape, a matchbook with at least one match missing, and a receipt reflecting purchases of duct tape and a bottle of lighter fluid that day. Police found a handcuff key in Robinson’s pocket.Robinson was sentenced to death. The Arizona Supreme Court affirmed, first rejecting “Batson” challenges to the dismissal of potential minority jurors. The court upheld the jury’s “especial cruelty” and its “heinous or depraved conduct” findings. The legislature’s decision to equate feticide with infanticide also makes B.H.’s murder senseless as a matter of law. Robinson’s double-counting argument failed. Although the jury was prohibited from weighing B.H.’s age twice as it “assesse[d] aggravation and mitigation” at the penalty phase, it was permitted to “use one fact to find multiple aggravators” at the aggravation phase. The court also rejected challenges to jury instructions and statements made by the prosecutor. View "State of Arizona v Robinson" on Justia Law

The Supreme Court affirmed Defendant's convictions for multiple counts of first degree murder and sentence of death, holding that no prejudicial error occurred in the proceedings below.After a ten-day trial, a jury found Defendant guilty of the 2012 first degree murders of Penelope Edwards and Troy Dunn under both premeditated and felony murder theories. After the penalty phase of trial, the jury returned death verdicts for both murders. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered during a traffic stop and any fruit of that search; (2) the trial court did not err in the way it conducted voir dire; (3) Defendant's evidentiary challenges were without merit; (4) one instance of prosecutorial error occurred, but the error was not prejudicial; (5) any error during the aggravation phase was harmless; and (6) Defendant's challenges to the death penalty were unavailing. View "State v. Thompson" on Justia Law