Justia Criminal Law Opinion Summaries

Appellees Randall and Penny West were charged with child abuse after an infant in their foster care died from severe head trauma. During their joint trial, each moved for an acquittal at the close of the Stateâs case and after the close of evidence. The trial court denied those motions. The jury found both guilty on child abuse charges. After the trial, Appellees renewed their motions for acquittal which this time was granted by the trial court. The court held that there was no evidence to prove who injured the child. The appellate court reversed the trial courtâs decision granting Appelleesâ motions. The appellate court used the Supreme Courtâs holding in the âHyderâ case. Upon review of this case, the Supreme Court overturned its holding in âState ex rel. Hyder v. Superior Courtâ (âHyderâ), which placed conditions on trial courtsâ granting of post-verdict motions for acquittal. The Court held that the âHyderâ case was now inconsistent with state law. In this case, the trial judge thoroughly explained his reasons for granting defendantsâ post-verdict motions. Because the appellate court reviewed the trial courtâs ruling under âHyderâ conditions, it did not determine whether the trial courtâs record reflected substantial evidence to warrant the convictions. The Supreme Court vacated the appellate courtâs decision, remanded the case for the lower court to address the sufficiency of the evidence and the merits of the trial courtâs decision.

Appellant Wayne Prince, Jr. was convicted of first degree murder for the death of his step-daughter and for the attempted murder of his wife. The jury found Appellant guilty, and the trial judge sentenced Appellant to death. The sentence was vacated and remanded by the Supreme Court. Under the law in effect when Appellant killed his step-daughter, the trial judge decided whether to impose the death penalty, but a jury needed to determine whether there were mitigating circumstances from the case that might warrant life imprisonment. A penalty-phase was impaneled, and it found no mitigating factors to spare Appellant from the death sentence. The second jury sentenced Appellant to death. Appellant appealed, citing among other issues that the second juryâs sentence gave the State a second chance to seek a death sentence thus violating the ex post facto clauses of the U.S. and Arizona Constitutions. Upon re-review, the Supreme Court was not persuaded by Appellantâs ex post facto argument, and affirmed the trial courtâs death sentence.

Appellant Clarence Dixon was convicted of first degree murder and sentenced to death. At trial, he represented himself. A jury found him guilty on all counts. When Appellant elected before trial to represent himself, the judge warned him that he would have sole responsibility for his defense, including examining and cross-examining witnesses. Appellant requested that an advisory counsel handle the examination of witnesses. The trial court rejected this proposal. On appeal, Appellant claimed multiple errors by the trial court entitled him to a new trial, including the trial courtâs denial of his proposed âhybrid representation.â The Supreme Court noted that âthere is no constitutional right to hybrid representation.â The Court found that the trial court did not abuse its discretion in denying Appellantâs motion. Finding no other errors from trial, the Court affirmed the lower courtâs decision and Appellantâs death sentence.