Justia Civil Rights Opinion Summaries

Articles Posted in Arizona Supreme Court
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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

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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

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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

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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

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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

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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

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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

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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

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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

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The Supreme Court affirmed Defendant's convictions and sentences for first-degree murder and child abuse, holding that no prejudicial error occurred during the trial proceedings.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress; (2) the trial court did not violate the Due Process Clause of the Fourteenth Amendment by admitting a pretrial identification of Defendant; (3) the trial court did not err in denying Defendant's Batson challenges to the State's peremptory strikes of two jurors; (4) the trial court did not err by admitting a video demonstrating the location and movement of Defendant's and the victim's cellphones on the day of the murder; (5) the trial court did not err by restricting Defendant's cross-examination of the State's former case agent; (6) the trial court did not commit fundamental error by failing to reinstruct the jury at the close of the aggravation stage; (7) substantial evidence supported the jury's finding that Defendant killed the victim for pecuniary gain; (8) the jury was properly instructed; (9) the State did not engage in prosecutorial error; and (10) the jury did not abuse its discretion in sentencing Defendant to death. View "State v. Smith" on Justia Law