Justia Criminal Law Opinion Summaries

The two defendants in this case were juveniles when they fatally shot their victims. Defendants were each convicted of first degree murder. Defendants were sentenced to natural life imprisonment under Ariz. Rev. Stat. 13-703, meaning they were not eligible for release. After Miller v. Alabama was decided, each defendant filed a petition for post-conviction relief under Ariz. R. Crim. P. 32.1(g). In each case, the trial court summarily denied relief, concluding that the sentencing court had complied with Miller and that any constitutional infirmity in Arizona’s sentencing scheme had been resolved by 2014 statutory amendments. The Supreme Court vacated the opinion of the court of appeals, reversed the trial court’s dismissal of the petitions for post-conviction relief, and remanded for further proceedings, holding that Defendants were entitled to evidentiary hearings on their Rule 32.1(g) petitions because they made colorable claims for relief based on Miller. View "State v. Valencia" on Justia Law

After a jury trial, Defendant was found guilty of second degree burglary. In the middle of deliberations and after the jurors stopped for the day, the parties agreed to replace one juror with an alternate juror. The jury reconvened the next morning with the alternate juror, but the trial court did not instruct the jurors “to begin deliberations anew” pursuant to Ariz. R. Crim. P. 13.5(h). Defendant did not object to the court’s failure to give the instruction. The court of appeals vacated Defendant’s conviction and sentence and remanded for a new trial, concluding that the trial court’s failure to instruct the jury to begin deliberations anew violated Defendant’s constitutional right to a unanimous verdict and was fundamental, prejudicial error. The Supreme Court vacated the court of appeals’ opinion and affirmed the conviction and sentence, holding that Defendant failed to show prejudice from the trial court’s failure to give the “deliberate-anew” instruction. View "State v. Dalton" on Justia Law

A grand jury indicted Jesse Mesa in May 2014 for first degree murder and other charges. Mesa was arraigned the same month. The State did not file a notice of intent to seek the death penalty, and trial was set. In April 2015, the State obtained a new indictment of Mesa alleging the same charges as the first indictment but adding other charges. Mesa was arraigned the next month. Thereafter, the State dismissed the 2014 charges. The State subsequently filed a timely notice of intent to seek the death penalty. Mesa moved to strike the State’s notice of intent, asserting that it was invalid because the State had not timely filed a notice after he was arraigned for the 2014 charges. The trial court denied the motion. The Supreme Court affirmed, holding (1) when the State complies with Ariz. R. Crim. P. 16.6 in dismissing a prosecution and obtains a new indictment, the time limits for filing a notice under Ariz. R. Crim. P. 15.1(i)(1) restart, absent bad faith by the State or prejudice to the defendant; and (2) the untimely filing of a death notice does not itself invalidate the notice but may result in sanctions, including an order striking the notice. View "Mesa v. Honorable Warren J. Granville" on Justia Law

This case concerned the warrantless search of the residence of Defendant, a probationer. As a result of the search Defendant was charged with felony possession of narcotic drugs for sale and other offenses. Defendant sought to suppress the items seized during the search. The trial court ultimately granted Defendant’s motion to suppress, concluding that the probation search was not supported by a reasonable suspicion and did not have a sufficient legal basis. The Supreme Court reversed, holding (1) a warrantless search of a probationer’s residence complies with the Fourth Amendment if it is reasonable under the totality of the circumstances, and its legality does not depend on whether the search is supported by reasonable suspicion; and (2) under the totality of the circumstances, the warrantless search conducted in this case was reasonable and thus constitutional. View "State v. Adair" on Justia Law

Sammantha Allen and John Allen, a married couple, were indicted by a grand jury for first degree felony murder. The indictment concurrently charged the Allens with multiple counts of child abuse. The State filed a notice of intent to seek the death penalty, alleging the child abuse offenses as “serious offense” aggravating circumstances under Ariz. Rev. Stat. 13-751(F)(2). At the Allens’ request, the trial court conducted a hearing under the procedures outlined in Chronis v. Steinle and determined that probable cause existed for the serious offense aggravators because the grand jury found that probable cause existed for the alleged aggravating circumstances. The court of appeals reversed, concluding that Sanchez v. Ainley required the trial court to independently determine whether probable cause existed for the serious offense aggravators. The Supreme Court vacated the court of appeals’ opinion and affirmed the judgment of the trial court, holding that the trial court must independently determine if a concurrently charged offense qualifies as a serious offense, but the court should accept the grand jury’s determination that probable cause exists for the concurrently charged offense. View "Allen v. Honorable Teresa A. Sanders" on Justia Law

After a jury trial, Defendant was found guilty of child molestation and sexual abuse of a minor under age fifteen. Under Ariz. Rev. Stat. 13-1407(E), it is a defense to a prosecution for sexual abuse or child molestation that a defendant was not motivated by a sexual interest. The court of appeals concluded that the trial court erred in instructing the jury that Defendant bore the burden of proving “his conduct was not motivated by a sexual interest” but that the error was harmless. The Supreme Court vacated the court of appeals’ opinion and affirmed Defendant’s convictions and sentences, holding (1) section 13-1407(E) provides an affirmative defense that a defendant must prove, and therefore, the State need not prove as an element of those crimes that a defendant’s conduct was motivated by a sexual interest; and (2) the trial court properly instructed the jury that Defendant was required to prove by a preponderance of the evidence that he was not motivated by a sexual interest. View "State v. Holle" on Justia Law

Defendant was charged with necrophilia and two counts of sexual assault. Defendant moved to suppress evidence of a video taken with his cell phone that he left in the victim’s apartment where he was an overnight guest, contending that the warrantless search of his phone was unconstitutional. The trial court granted Defendant’s motion and suppressed of the video and of statements Defendant made to the police about that video, holding that the evidence resulted from an illegal search. The court of appeals reversed, ruling that the warrantless search of the phone was permissible because Defendant did not have a reasonable expectation of privacy in either the victim’s apartment or his cell phone. The Supreme Court reversed, holding (1) Defendant had a reasonable expectation of privacy in his phone; (2) as an overnight guest, Defendant had a legitimate expectation of privacy in the apartment; and (3) no exception to the warrant requirement existed, and therefore, the good-faith exception to the exclusionary rule did not apply. View "State v. Peoples" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and kidnapping and sentenced to death. For reasons unrelated to this appeal, the Supreme Court remanded for a new penalty phase trial on the murder conviction. After a penalty phase retrial, a jury again determined that Defendant should be sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in allowing Defendant to represent himself during the penalty phase on remand; (2) the trial court did not err by permitting Defendant to waive the presentation of mitigation evidence; (3) the trial court’s denial of Defendant’s motion to strike a certain aggravator was not erroneous; (4) the trial court’s response to a jury question during deliberations was not fundamental error; and (5) there was no prosecutorial misconduct. View "State v. Gunches" on Justia Law

Defendant was charged with importation of marijuana, transportation of marijuana for sale, and possession of drug paraphernalia. Before trial, Defendant notified the court that he intended to raise a duress defense by testifying that armed smugglers had forced him to carry the drugs. The trial court precluded Defendant from raising the duress defense or describing any related anticipated testimony in his opening statement on the grounds that Defendant might change his mind about testifying. The jury subsequently found Defendant guilty of transportation of marijuana and possession of drug paraphernalia. The court of appeals affirmed. The Supreme Court vacated the court of appeals’ decision, holding that the trial court erred in so limiting Defendant’s opening statement. Remanded to allow the court of appeals to consider whether the error was harmless. View "State v. Pedroza-Perez" 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