Justia Constitutional Law Opinion Summaries

Articles Posted in Arizona Supreme Court

by
The Supreme Court affirmed Defendant’s convictions and sentences, holding that the good-faith exception to the exclusionary rule applies in a prosecution for driving under the influence (DUI) to admit blood evidence unconstitutionally obtained after State v. Butler, 232 Ariz. 84 (2013), but before State v. Valenzuela (Valenzuela II), 239 Ariz. 299 (2016). Before her trial, Defendant filed a motion to suppress all evidence obtained through a warrantless search and seizure of her blood sample. The trial court denied the motion, and Defendant was convicted of aggravated DUI while impaired to the slightest degree and one count of aggravated DUI with blood-alcohol concentration of .08 or more. Defendant appealed, arguing that her blood was obtained without a warrant and without valid consent and that the good-faith exception recognized in Valenzuela II did not apply. The Supreme Court affirmed, holding that the deterrent purpose of the exclusionary rule did not apply in this case because the police followed binding appellate precedent that persisted in the wake of Butler. View "State v. Weakland" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals in this class action, holding that the surcharge imposed by Maricopa County on car rental agencies to fund a stadium and other sports and tourism-related ventures violated neither the dormant Commerce Clause of the United States Constitution nor the anti-diversion provision of the Arizona Constitution. Plaintiff, which rented vehicles in Maricopa County and paid the car rental surcharges, sued the Arizona Department of Revenue seeking refunds and injunctive relief for all similarly situated car rental companies. The tax court certified the class and granted summary judgment for Plaintiff, concluding that the surcharge did not violate the dormant Commerce Clause but did violate the anti-diversion provision. The court of appeals reversed, concluding that the surcharge did not violate the anti-diversion provision. The Supreme Court affirmed, concluding that the Arizona Constitution’s anti-diversion clause, which requires that revenues derived from taxes relating to the operation of motor vehicles must be allocated for public highways, does not apply to a tax relating to the operation of motor vehicles. View "Saban Rent-a-Car LLC v. Arizona Department of Revenue" on Justia Law

by
In this opinion, the Supreme Court explained its ruling that House Concurrent Resolution 2007 (HCR 2007) does not violate the constitutional “single subject rule,” holding that because the two provisions of HCR 2007 are reasonably related to one general subject, the measure satisfies the single subject rule. Challengers filed suit requesting the trial court to enjoin the Secretary of State from placing HCR 2007 on the ballot, alleging that the measure violated the single subject rule contained in Ariz. Const. art. IV, part 2. Relying on Arizona Chamber of Commerce & Industry v. Kiley, 242 Ariz. 533 (2017), the trial court concluded that the rule does not apply to HCR 2007. The Supreme Court affirmed, holding (1) measures referred to the people by the legislature are “acts” subject to the single subject rule; and (2) HCR 2007 satisfied the single subject rule. View "Hoffman v. Reagan" on Justia Law

by
After granting the State’s motion to conduct a new independent review of Defendant’s two death sentences, the Supreme Court affirmed the sentences, holding that there was no error in the trial court’s findings of aggravation and mitigation and that the death sentence was not an abuse of discretion. The Supreme Court previously affirmed Defendant’s sentences on independent review. However, the Ninth Circuit Court of Appeals held that the Court applied an unconstitutional “causal nexus” test to Defendant’s mitigation evidence. Upon conducting a new independent review of Defendant’s death sentences, the Supreme Court affirmed, holding that the mitigating evidence was not sufficiently substantial to warrant leniency and that the aggravators weighed heavily in favor of the death sentence. View "State v. McKinney" on Justia Law

by
The Supreme Court affirmed Defendant’s convictions of first degree murder, discharge of a firearm at a structure, and misconduct involving weapons and sentences of death for the murder and concurrent prison sentences for the remaining convictions to be served consecutively to the death sentence. The Court held (1) the trial court did not err by failing to sue sponte sever the misconduct-involving-weapons charge; (2) the trial court did not abuse its discretion during voir dire; (3) there was no error in the jury instructions; (4) the trial judge did not abuse his discretion in denying Defendant’s motion to vacate judgment without holding an evidentiary hearing; (5) the cumulative effect of any instances of prosecutorial misconduct during trial did not render it unfair; and (6) the death sentence was not an abuse of discretion. View "State v. Valenzuela" on Justia Law

by
The Supreme Court affirmed Defendant’s convictions for first degree murder and child abuse and Defendant’s sentence of death, holding that there was no reversible error in the proceedings below. Specifically, the Court held (1) the trial court did not commit an error under Simmons v. South Carolina, 512 U.S. 154 (1994) by failing to instruct the jury that Defendant was ineligible after instructing the jurors that a life sentence includes the “possibility of release from prison after serving 35 years”; (2) there was no error in empaneling a juror who was a convicted felon; (3) there was no merit to Defendant’s challenges to each of the aggravating factors found by the jury; (4) the trial court did not commit reversible error in its evidentiary rulings; (5) there was sufficient evidence to support the convictions; (6) the prosecutor did not violate Defendant’s due process rights by misstating the law on mitigation during the penalty phase; (7) Defendant’s claim of cumulative prosecutorial misconduct failed; and (8) the jury did not abuse its discretion in sentencing Defendant to death. View "State v. Sanders" on Justia Law

by
The Supreme Court affirmed Defendant’s conviction for transportation of a narcotic drug for sale, holding that the trial court’s remedy for a Batson violation of reinstating wrongfully excluded jurors to the venire was proper. During Defendant’s trial, the prosecutor violated Defendant’s equal protection rights by using peremptory strikes to remove Hispanic jurors from the venire, in violation of Batson v. Kentucky, 476 U.S. 79 (1986). Defendant moved for a mistrial and dismissal of the entire venire. The trial court denied the motion and empaneled the first nine jurors who had not been struck, including two of the reinstated jurors. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court’s remedy of restoring the impermissibly excluded juror to their prior places on the venire and forfeiting the State’s peremptory challenges was sufficient. View "State v. Urrea" on Justia Law

by
Ariz. Rev. Stat. 15-108(A), which makes it unlawful for a person, including a qualified Arizona Medical Marijuana Act (AMMA) cardholder, to possess or use marijuana on the campus of any public university, college, community college or postsecondary educational institution, violates Arizona’s Voter Protection Act (VPA) with respect to AMMA-compliant marijuana possession or use. Defendant, an AMMA cardholder, was convicted ofpossessing marijuana in his dormitory on the campus of Arizona State University. The Supreme Court vacated the conviction, holding (1) section 15-108(A) is unconstitutional under the VPA because the statute amends the AMMA by re-criminalizing AMMA cardholders’ marijuana possession on public college and university campuses; and (2) therefore, the statute is unconstitutional as applied to Defendant. View "State v. Maestas" on Justia Law

by
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

by
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