Justia Civil Rights Opinion Summaries

Articles Posted in Arizona Supreme Court
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After a jury trial, Defendant was convicted of the murders of three individuals and of attempted murder. Defendant was sentenced to death for each murder. The Supreme Court affirmed, holding, inter alia, that (1) the trial court sufficiently inquired into the bases for Defendant's requests for a change of counsel and correctly denied the requests; (2) the trial court did not err in refusing to permit Defendant to impeach the surviving victim with her prior inconsistent statements absent an offer of proof of the prior statements; (3) the trial court did not err in admitting evidence impeaching a witness as substantive evidence of Defendant's guilt; (4) the State presented sufficient evidence of premeditation; and (5) the jury did not abuse its discretion by determining that the mitigation presented by Defendant was not sufficiently substantial to call for leniency. View "State v. Hernandez" on Justia Law

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After a jury trial, Defendant was convicted of three counts of child abuse, two counts of concealing a dead body, and two counts of first degree murder. The jury also found three aggravating factors, including the young age of the victims, ages three and four. Defendant was sentenced to death for the two murders. The Supreme Court affirmed Defendant's convictions and sentences, holding, inter alia, that (1) the trial court did not err by dismissing some jurors improperly and failing to dismiss others; (2) the trial court did not err by denying Defendant's request for a change of venue based on presumed and actual prejudice; (3) the trial court did not err by refusing to suppress Defendant's post-arrest statements; (4) the prosecution did not commit prejudicial misconduct; (5) the evidence was sufficient to convict Defendant of the child abuse charges; (6) the trial court did not fundamentally err in its aggravation phase jury instructions; and (7) the jury did not abuse its discretion by finding the mitigating factors presented by Defendant insufficient to warrant leniency. View "State v. Payne" on Justia Law

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After a jury trial, Defendant was convicted of two counts of first degree murder and eight other felonies. For his crimes, Defendant was sentenced to death and prison terms. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not abuse its discretion in its pretrial rulings; (2) the trial court did not err in instructing the jury during the aggravation phase; (3) the prosecutor did not misstate the law in his closing argument; (4) the trial court did not abuse its discretion in refusing to inform the jury of Defendant's willingness to waive parole eligibility; (5) the trial court did not abuse its discretion in excluding victim impact evidence; (5) the jury's finding that three aggravating circumstances applied was supported by the evidence with respect to each murder; and (6) the jury did not abuse its discretion in imposing the death penalty for each murder. View "State v. Benson" on Justia Law

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This case involved the intersection of municipal zoning regulations and the right of tattoo artists to ply their trade. After the City of Mesa denied Plaintiffs a permit to operate a tattoo parlor, Plaintiffs filed this action alleging violations of their rights to free speech, due process, and equal protection. The superior court dismissed the complaint for failing to state a claim upon which relief can be granted. Recognizing that tattooing involves constitutionally protected speech, the Supreme Court vacated the court of appeals and reversed the judgment of the superior court, holding that the superior court erred by dismissing the complaint as a matter of law. Remanded. View "Coleman v. City of Mesa" on Justia Law

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A jury found Defendant guilty of one count of first degree burglary, four counts of aggravated assault, four counts of kidnapping, one count of theft, and one count of first degree murder. After a mistrial in the penalty phase, a second jury determined Defendant should be sentenced to death. The Supreme Court affirmed Defendant's convictions and sentences, holding, inter alia, that (1) the trial court did not err in denying Defendant's motions to strike prospective jurors; (2) the trial court did not abuse its discretion in admitting a brown bag with ammunition; (3) the prosecutor did not engage in misconduct warranting reversal; and (4) the death sentence was appropriate.

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A jury found Defendant guilty of felony murder and other crimes. Defendant was sentenced to death for the murder and to prison terms on the other convictions. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the trial court did not err in permitting the State's medical expert to testify; (2) the trial court did not err by denying Defendant's request for an Enmund/Tison jury instruction at the aggravation phase of trial; (3) Defendant's waiver of his right to present mitigation was voluntary, knowing, and informed; and (4) the jury did not abuse its discretion in concluding that the mitigating circumstances were not sufficiently substantial to call for leniency.

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On January 27, 2012, the Yuma County Superior Court disqualified Alejandrina Cabrera under Ariz. Rev. Stat. 38-201(C) from appearing on the ballot as a candidate for the San Luis City Council. Concluding that section 38-201(C)'s language requirement must be read "in the context of the political office at issue," the court found that Cabrera was not sufficiently proficient in English to perform as a city council member for San Luis. The Supreme Court affirmed, holding, in relevant part, that (1) the trial court correctly interpreted section 38-201(C); and (2) the trial court's interpretation of the statute did not unconstitutionally violate Cabrera's right to participate in government.

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A jury found Defendant guilty of first degree burglary, kidnapping, and two counts of first degree murder. Defendant was sentenced to death on both murder counts and to prison terms on the other counts. The Supreme Court affirmed Defendant's convictions and sentences, holding, among other things, (1) the trial court did not err in denying Defendant's challenges to the State's peremptory strikes of two minority jurors; (2) the evidence was sufficient to sustain Defendant's convictions; (3) the trial court did prejudicially err by admitting evidence of other acts that occurred on the weekend of the murders; (4) the trial court did not err by denying Defendant's motion for mistrial after three jurors inadvertently saw Defendant during the guilt phase exiting an elevator accompanied by law enforcement officers and wearing jail garb; and (5) the sentences were appropriate.

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In 2009, Defendant was sentenced to death for first degree murder of a fellow inmate. The Supreme Court affirmed Defendant's conviction and sentence, holding, among other things, (1) the trial court did not abuse its discretion by denying Defendant his successive motions to continue the trial, as Defendant failed to establish prejudice from the denials; (2) the State presented sufficient evidence of premeditation; (3) the trial court did not err in permitting the State to present evidence of other bad acts Defendant had committed while incarcerated; (4) the trial court did not abuse its discretion in admitting rebuttal evidence that Defendant had attacked and seriously injured another inmate; and (5) the jury did not abuse its discretion in determining that death was the appropriate sentence.

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A jury found Defendant guilty of the first degree murder of his girlfriend. Defendant was sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence, holding, among other things, that the trial court did not err by (1) precluding Defendant from asking prospective jurors what factors they would find aggravating or mitigating; (2) requiring Defendant to mention mitigation in a hypothetical question he asked; (3) striking for cause a juror who worked for the public defender's office and had expressed strong opposition to the death penalty; (4) denying Defendant's request for a mistrial based on prosecutorial misconduct; and (5) denying Defendant's requested jury instruction on the lesser included offense of manslaughter.