opinion analysis

The Supreme Court, which was only a second opinion day for its 2022-23 term, provided a rare victory for convicted petitioners, making it appropriate for federal courts to step in if state courts deny their petitions. provided a clear example of when federal law.and 5-4 Judgment of Cruz vs Arizona, the court ruled in favor of Arizona death row inmate John Montenegro Cruz. As a result of the court’s ruling, approximately 30 individuals in similar circumstances to Cruz will be entitled to new sentencing hearings.

Justice Sonia Sotomayor prepared the opinion and was signed by Chief Justices John Roberts, Elena Kagan, Brett Kavanaugh, and Ketanji Brown Jackson.

By way of background, in 2005, a Pima County jury found Cruz guilty of first-degree murder for the death of a police officer. A jury was then tasked with determining the appropriate verdict. According to Arizona law, death row inmates who, like Cruz, committed crimes after 1993 were (and still are) ineligible for parole. Therefore, the jury’s choice of sentence was life imprisonment or the death penalty. During the trial, Cruz repeatedly tried to tell jurors that he would not be eligible for parole if he refused the death sentence. the judge refused. This was not a trivial detail. about ten years ago, Simmons v. South Carolinathe Supreme Court ruled that jurors had a constitutional right to be notified that they were ineligible for parole if they sentenced him to life imprisonment.

Instead, an Arizona judge instructed the jury that Cruz had three possible sentences: (1) the death penalty; (2) life imprisonment without the possibility of parole; or (3) life imprisonment with the possibility of parole after 25 years. This proved not only inaccurate, but fatal. The jury sentenced Cruz to death and believed that if they refused to do so, the judge would choose between two remaining sentences. It points out that he spoke to the media shortly after the trial, describing it as a “heartbreaking” decision that brought tears to everyone involved. Jurors expressed a desire to “vote for life imprisonment without the possibility of parole”, but lamented that “they were not given that option”.

Cruz appealed to state court, arguing that the judge denied him his constitutional right to due process when he prevented the jury from knowing he was ineligible for parole. , reasoned that such information would have been able to refute the reasoning that if he escaped the death penalty, he would somehow endanger the public. has dismissed appeals from other death-sentenced petitioners who experienced similar problems in . Simmons To support his reasoning in vain. This changed when the Supreme Court issued a summary reversal judgment. Lynch vs Arizona Without entertaining any additional briefings or oral arguments, the court informed Arizona that the state had mishandled the parole ineligibility issue.

Cruz then filed a second appeal in state court. Arizona imposes many restrictions on such claims for post-conviction relief. Arizona Criminal Procedure Rule 32.1(g) permits the petitioner to challenge the judgment if “there has been a material change in law that, if applied to the defendant’s case, would likely overturn the defendant’s . . . judgment.” Cruz relied on that rule, arguing that: Lynch This represented a “substantial change in law” and required Arizona to enforce Simmons To deal with his case and allow him a new sentencing hearing. An Arizona court disagreed, so Cruise went to the Supreme Court.

The question for the judge was whether Arizona’s denial of relief was based on another state law basis and was therefore insulated from Supreme Court review. The Supreme Court does not take part in matters of federal law when the state court’s decisions are justified by “independent” and “appropriate” provisions of state law. In this case, the state argued that the Arizona Supreme Court’s decision denying Cruz relief under Rule 32.1(g) constituted the appropriate state law basis for the decision. Sotomayor, along with his two other liberal justices and his two conservatives, rejected the claim.

Her opinion pointed to the state court’s previous interpretation of Rule 32.1(g) that Arizona applied the rule to a “transformative event” that constituted a “clear break from the past.”The fact that Arizona denied the application Simmons more than 20 years until Lynch signaled it Lynch Because it was a “transformation event,” it fell directly within Rule 32.1(g). To hold otherwise constitutes a departure from the way the Arizona Supreme Court has interpreted Rule 32.1(g) in other cases. Lynch Should have been “frank”. “It’s hard to imagine a clear break from the past,” she wrote.

The Court held that the application of Arizona’s 32.1(g) Lynch It was so novel and unpredictable that it declined to say whether the Arizona decision constituted an “independent” state law basis for the decision. Simmons and Lynchwhether the Arizona decision discriminated against federal law.

Justice Amy Coney Barrett wrote the dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Neil Gorsuch. The dissenting opinion seemed to suggest that courts should not consider state courts’ interpretation of state law, even if federal law is involved. It takes the notion of inequality to the extreme and cuts out the Supreme Court’s role in checking state courts when necessary.

On a practical level, the decision reversed Arizona’s ruling denying Cruz relief and remanded the case back to state court with instructions to apply. Simmons (via Lynch). The decision does not affect Cruz’s conviction, but does give him the right to a new sentencing hearing. At that hearing, the jury must learn that Cruz is ineligible for parole if he escapes the death penalty. This decision not only has a direct and immediate effect on Cruz’s case, but also other Arizona states where petitioners, like Cruz, were sentenced to death by juries who did not know they were ineligible for parole. It also affects about 30 death row petitioners in the state. These individuals make up more than a quarter of Arizona’s death row population. They are all entitled to a new sentencing hearing, a time and resource intensive procedure. The far-reaching implications of this decision in Arizona’s death penalty cases could prompt the question of whether the state should continue to operate the death penalty scheme.