Justia Civil Rights Opinion Summaries

Granvil Wallace pleaded guilty and was sentenced to death by the trial judge for three murders. The Supreme Court subsequently reduced the death sentence for one murder count to life in prison because the evidence was insufficient to prove an aggravating circumstance as to that murder. In this appeal the Supreme Court vacated Wallace's remaining two death sentences and sentenced him to consecutive life terms of imprisonment, holding that the State had no established beyond a reasonable doubt that Wallace inflicted gratuitous violence on the two victims, and thus, the murders were not heinous or depraved under Ariz. Rev. Stat. 13-751(F)(6), the sole aggravating factor alleged in this case.

A jury found Benjamin Cota guilty of two counts of first degree murer, two counts of armed robbery, one count of possession of narcotics, and one count of unlawful flight. Cota was sentenced to death on one first degree murder count and to prison terms for the other counts. The trial judge stated that he believed Arizona law "required" him to make the sentences on the "non-capital" counts consecutive, and he did so on all but the flight count. The Supreme Court affirmed Cota's convictions and death sentence but remanded for resentencing on the non-capital counts, holding that although the judge here imposed one concurrent sentence, the Court was not convinced the judge was aware of his discretion to do the same with all other sentences under Ariz. Rev. Stat. 13-708.

After a jury trial, Jahmari Manuel was convicted of first degree murder and other offenses related to the death of Darrell Willeford. The jury determined that Manuel should be sentenced to death for the murder. The Supreme Court affirmed Manuel's convictions and sentences, holding (1) the trial court did not err in denying Manuel's notice of change of judge because the notice was untimely under Ariz. R. Crim. P. 10.2(a); (2) the trial court did not err in denying Manuel's motion to suppress a pistol found in his hotel room when he was arrested because the officer discovered the gun in plain view; (3) Manuel did not show that certain remarks that the prosecutor made at trial caused prejudice sufficient to constitute fundamental error, and the instances of alleged misconduct did not warrant reversal when considered cumulatively; (4) the trial judge correctly answered a juror's question in the penalty phase; (5) the judge did not abuse her discretion in denying Manuel's motion for new trial; and (6) the jury did not abuse its discretion by determining that Manuel should be sentenced to death.

Clifford Ochser brought a civil rights action against two deputy sheriffs for arresting him on a warrant that had been quashed some thirteen months earlier. The trial court granted the deputies' motion for summary judgment, ruling that an arresting officer is entitled to qualified immunity when the arrest is made on a facially valid warrant. A divided court of appeals affirmed. At issue on appeal was the scope of qualified immunity in the context of arrests made pursuant to a facially valid but quashed warrant. The Supreme Court affirmed, holding that although Ochser's arrest was an unreasonable seizure prohibited by the Fourth Amendment, the deputies were entitled to qualified immunity because then-existing law did not clearly establish the constitutionality of their actions.

Douglas Eddington was charged as an accomplice in the murder of the son of a Tucson police officer. During voir dire, one potential juror stated he was employed as a deputy sheriff with the law enforcement agency that had investigated the crime. The trial court denied Eddington's motion to strike the deputy for cause, and the jury ultimately found Eddington guilty of second degree murder. The court of appeals held that the trial court erred in refusing to strike the deputy. The Supreme Court affirmed, holding that a peace officer currently employed by the law enforcement agency that investigated the case is an "interested person," who is disqualified from sitting as a juror by Ariz. Rev. Stat. 21-211(2).

After Petitioner was indicted on child abuse, the State extended a plea offer in May 2009 without imposing a deadline for its acceptance. A new prosecutor was assigned to the case in August 2009 and notified Petitioner that the offer was no longer available. Petitioner moved under Ariz. R. Crim. P. 15.8, which authorizes sanctions if a prosecutor imposes a plea deadline and fails to disclose certain information to the defense at least thirty days before the offer lapses, to preclude any evidence disclosed after July 29, 2009. The trial court denied the motion. The court of appeals granted relief to Petitioner, holding that rule 15.8 applied because the State effectively imposed a deadline on the offer by withdrawing it. The Supreme Court vacated the court of appeals, holding (1) rule 15.8 does not apply when a prosecutor withdraws an open-ended plea offer; and (2) in such a situation, Ariz. R. Crim. P. 15.7 governs the imposition of sanctions for any failure to make required disclosures. Remanded.

A jury found James Styers guilty of the 1989 murder, conspiracy to commit first degree murder, kidnapping, and child abuse of a four-year-old. After finding three aggravating factors and no mitigating circumstances, the trial judge sentenced Styers to death. The Supreme Court affirmed the sentence. Styers then filed a habeas corpus petition, which the district court denied. The court of appeals reversed and granted relief, finding that in independently reviewing Styers' death sentence, the Supreme Court erroneously refused to consider as a mitigating circumstance the PTSD Styers suffered from as a result of military service in Vietnam. The Supreme Court granted the state's request to conduct a new independent review. On review, the Court affirmed Styers' sentence, holding that Styers' PTSD, in combination with all other mitigating evidence previously considered by the Court, was not sufficient to warrant leniency in light of the aggravating factors proven in this case.

Michael Hummons agreed to speak with a police officer on the sidewalk. During the encounter the officer discovered an outstanding warrant for Hummons' arrest. The officer arrested Hummons, and in a search incident to that arrest discovered drugs and drug paraphernalia in Hummons' backpack. At trial Hummons moved to suppress the evidence, arguing it was obtained as the result of an illegal detention. The trial court denied the motion, finding the officer's encounter with Hummons consensual. The court of appeals affirmed. The Supreme Court vacated the judgment of the appellate court, holding that the court overemphasized the importance the warrant as an intervening circumstance in dissipating the taint of any prior illegality and that the court should have applied the third Brown v. Illinois factor, i.e., the purpose and flagrancy of the official misconduct. The Court held the totality of the circumstances militated against suppressing the evidence and upheld the judgment of the trial court.