Justia Constitutional Law Opinion Summaries

The Supreme Court held that four legislative budget reconciliation bills (BRBs) - House Bill (HB) 2898, Senate Bill (SB) 1824, SB 1825, and SB 1819 - violated the Arizona Constitution's title requirement and were therefore void in part and that SB 1819 violated the constitutional single subject rule.Plaintiffs - the Arizona School Boards Association and other organizations and citizens - challenged four of the eight BRBs included in the 2022 budget approved by the legislature and signed by the Governor. The trial court ruled that the challenged sections of all four BRBs violated the title requirement and that the entirety of SB 1819 violated the single subject rule. The Supreme Court affirmed, holding that the trial court did not err in ruling that the noncompliant portions of HB 2898, SB 1824, SB 1825, and SB 1819 were unconstitutional in violation of the title requirement and that SB 1819 was unconstitutional and void in violation of the single subject rule. View "Arizona School Boards Ass'n, Inc. v. State" on Justia Law

The Supreme Court held that the direct funding provision of Proposition 208 did not fall within the constitutional definition of grants in Ariz. Const. art. IX, 21 (the Education Expenditure Clause) and was therefore unconstitutional to the extent it mandated expanding tax revenues in violation of the Education Expenditure Clause.Proposition 208 was a citizens' initiative passed in 2020 imposing an income tax purchase on high-income Arizona taxpayers to provide direct funding to schools. Petitioners brought this action challenging the constitutionality of the tax and the initiative's characterization of the direct funding as "grants" exempt from the Education Expenditure Clause and seeking to enjoin the collection of that tax pending the resolution of their challenge. The Supreme Court held (1) because Ariz. Rev. Stat. 15-1285 incorrectly characterizes the allocated monies in order to exempt Proposition 208 from the Education Expenditure Clause, it is facially unconstitutional; (2) the remaining non-revenue related provisions of Proposition 208 are not severable; (3) this Court declines to enjoin the imposition of the tax pending further proceedings; and (4) Proposition 208 does not violate the Tax Enactment Clause of the Arizona Constitution, and therefore, the bicameralism, presentment, and supermajority requirements found therein are inapplicable. View "Fann v. State" on Justia Law

The Supreme Court vacated the opinion of the court of appeals affirming the decision of the trial court summarily denying relief as to Petitioner's petition for post-conviction relief and affirmed the trial court's ruling dismissing Petitioner's PCR petition, holding that Petitioner's claims did not warrant relief.Specifically, the Supreme Court held (1) a defendant need not present a standard of care expert affidavit to support his ineffective assistance of counsel claim, and the trial court did not abuse its discretion in ruling that Petitioner failed to present colorable IAC claims; (2) Perry v. New Hampshire, 565 U.S. 228 (2012), did not cause a significant change in Arizona law; and (3) Ariz. Rev. Stat. 13-4234(G) unconstitutionally conflicts with the procedure established by the Supreme Court in Ariz. R. Crim. P. 32.4. View "State v. Bigger" on Justia Law

The Supreme Court affirmed Defendant's conviction of resisting arrest, holding that neither federal or Arizona Batson jurisprudence requires a trial court to expressly address a demeanor-based justification when two race-neutral reasons are offered, the non-demeanor-based justification is explicitly deemed credible, and there is no finding that the demeanor-based justification is pretextual.On appeal, Defendant argued that the prosecutor's disparate treatment of jurors and failure to conduct voir dire on the issue of prior jury service demonstrated that the prosecutor had discriminatory intent during jury selection. The court of appeals remanded the case on the grounds that the trial court did not expressly determine whether the proffered justifications were not only race-neutral but also credible. The Supreme Court vacated the court of appeals' opinion and affirmed the trial court's denial of Defendant's Batson challenge, holding that the trial court satisfied its obligations under federal and Arizona Batson jurisprudence. View "State v. Porter" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendant's conviction and sentences and remanding for a new trial, holding that the trial court did not adequately confirm that Defendant waived his right to conflict-free counsel.Defendant and his co-defendant were charged with conspiracy, possession and transportation of marijuana for sale, and unlawful possession of drug paraphernalia. At Defendant's arraignment, the prosecutor noted his concern about one attorney representing both codefendants were they were competing defenses. Defense counsel dismissed the concerns because the codefendants had signed a waiver of potential conflict after being advised of their rights. The jury ultimately convicted both defendants on all counts. The Supreme Court vacated the convictions, holding that the joint representation presented an actual conflict that violated Defendant's Sixth Amendment right to conflict-free representation. The Supreme Court affirmed, holding that Defendant did not knowingly and intelligently waive the right to conflict-free counsel. View "State v. Duffy" on Justia Law

The Supreme Court reversed the judgment of the post-conviction court granting Defendant post-conviction relief (PCR) on the ground that counsel's ineffectiveness challenged Defendant, holding that Defendant's lawyers were not deficient by failing to challenge a challenged jury instruction.Defendant was convicted of five counts of first-degree murder and other charges. The jury returned death sentence verdicts on each murder count. Defendant later brought his petition for PCR, claiming that his counsel were constitutionally ineffective for failing to object to the Revised Arizona Jury Instruction's (RAJI) definition of "significantly impaired." The post-conviction court concluded that the RAJI had misstated the law by using the word "prevented" and that both trial and appellate counsel were constitutionally ineffective for failing to challenge the instruction. The Supreme Court reversed, holding that even if Defendant's counsel were deficient for failing to challenge the RAJI, Defendant's defense was not prejudiced. View "State v. Miller" on Justia Law

The Supreme Court held that Ariz. Rev. Stat. 28-672(G), which limits the amount of restitution that can be awarded to a victim for an unconstitutional limitation on the right to receive restitution or a valid legislative enactment, is unconstitutional and void.The Victims' Bill of Rights (VBR), Ariz. Const. art. II, 2.1, guarantees a victim's right to receive prompt restitution for loss or injury caused by a defendant's criminal conduct and authorizes the legislature to enact laws to define, implement, preserve and protect victims' rights. At issue was whether section 28-672(G), which limits the restitution that can be awarded to a victim for loss resulting from a violation of specified traffic offenses, was unconstitutional, either as a limitation on the right to receive restitution or a valid legislative enactment. The Supreme Court held (1) the constitutional right under the VBR to receive restitution is a right to receive the full amount of economic loss or injury caused by a defendant's criminal conduct; and (2) therefore, section 28-672(G)'s limitation on a restitution award is an unconstitutional limitation on the right to receive prompt restitution, as guaranteed by the VBR. View "State v. Patel" on Justia Law

The Supreme Court held that Ariz. Rev. Stat. 16-204.01 cannot apply to require a city to consolidate local elections with state and national elections if the city's charter provides otherwise.Section 16-204.01 requires political subdivisions to consolidate local elections with state and national elections when voter turnout for local elections significantly decreases. At issue in this case was whether the home rule charter provision barred application of section 16-204.01 to the City of Tuscon, whose charter required electing local officials on non-statewide election dates. The Supreme Court held that section 16-204.01 was unconstitutional as applied to the City charter and therefore could not preempt the City's election-scheduling provision. View "State ex rel. Brnovich v. City of Tucson" on Justia Law

The Supreme Court held that the City of Peoria violated Ariz. Const. art. IX, section 7, the Gift Clause, by spending public funds to induce a private university to open a branch campus in Peoria.In 2015, Huntington University, Inc. (HU), an accredited private institution based in Indiana, and the City entered into an agreement for HU to open a campus in Peoria. In return, the City promised to pay HU almost $2 million for developing the campus and programs. Plaintiffs, Peoria taxpayers, brought this lawsuit asserting that the City's payments to HU violated the Gift Clause. The trial court granted summary judgment for the City, and the court of appeals affirmed. The Supreme Court reversed and remanded with directions to enter summary judgment in favor of Plaintiffs, holding that the City's payments to HU violated the Gift Clause. View "Schires v. Carlat" on Justia Law

The Supreme Court affirmed Defendant's convictions, holding that neither the United States nor the Arizona Constitution requires a search warrant or court order for a law enforcement officer to obtain either a user's Internet Protocol (IP) address or subscriber information the user voluntarily provides to an Internet Service Provider (ISP) as a condition or attribute of service.Defendant was indicted on twenty counts of sexual exploitation of a minor under fifteen years of age. Defendant filed a motion to suppress on the grounds that the United States Fourth Amendment and Ariz. Const. art. II, 8 required a warrant or court order to obtain his IP address and ISP subscriber information. The motion was denied, and a jury convicted Defendant on all counts. The court of appeals affirmed. The Supreme Court affirmed, holding that the State lawfully obtained the challenged information with a valid federal administrative subpoena because neither the Fourth Amendment nor article 2, section 8 of the Arizona Constitution requires law enforcement officials to secure a search warrant or court order to obtain IP addresses or subscriber information voluntarily provided to ISPs as a condition or attribute of service. View "State v. Mixton" on Justia Law