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Cruz v. Arizona

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Supreme Court of the United States
Cruz v. Arizona
Term: 2022
Important Dates
Argued: November 1, 2022
Decided: February 22, 2023
Outcome
Vacated and remanded
Vote
5-4
Majority
Sonia Sotomayor • Chief Justice John Roberts • Elena Kagan • Brett Kavanaugh • Ketanji Brown Jackson
Dissenting
Amy Coney Barrett • Clarence Thomas • Samuel Alito • Neil Gorsuch

Cruz v. Arizona is a case that was decided by the Supreme Court of the United States on February 22, 2023, during the court's October 2022-2023 term. The case was argued before the court on November 1, 2022. The court vacated and remanded the decision of the Arizona Supreme Court in a 5-4 ruling, holding that the Arizona Supreme Court’s holding that Lynch v. Arizona (2016) was not a significant change in the law to allow John Montenegro Cruz to file a successive petition for state postconviction relief under Arizona Rule of Criminal Procedure 32.1(g) is not adequate to support that claim. Justice Sonia Sotomayor delivered the majority opinion of the court. Justice Amy Coney Barrett filed a dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Neil Gorsuch.[1][2] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: John Montenegro Cruz was sentenced to death in 2005. Cruz argued that he was unable to inform the jury that if he were given a sentence of life in prison, he would be ineligible for parole. After several appeals, Cruz petitioned the U.S. Supreme Court to review his case. Cruz argued the Arizona Supreme Court violated U.S. Supreme Court precedent from two previous cases. Click here to learn more about the case's background.
  • The issue: The case concerned the sentencing of Cruz and U.S. Supreme Court cases Simmons v. South Carolina (1994) and Lynch v. Arizona (2016).
  • The questions presented: "Whether the Arizona Supreme Court’s holding that Arizona Rule of Criminal Procedure 32.1(g) precluded post-conviction relief is an adequate and independent state-law ground for the judgment."[3]
  • The outcome: the Arizona Supreme Court’s holding that Lynch v. Arizona (2016) was not a significant change in the law to allow John Montenegro Cruz to file a successive petition for state postconviction relief under Arizona Rule of Criminal Procedure 32.1(g) is not adequate to support that claim.


    • The case came on a writ of certiorari to the Arizona Supreme Court. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • February 22, 2023: The U.S. Supreme Court vacated and remanded the Arizona Supreme Court's ruling
    • November 1, 2022: The U.S. Supreme Court heard oral argument.
    • March 28, 2022: The U.S. Supreme Court agreed to hear the case.
    • November 22, 2021: John Montenegro Cruz, the petitioner, appealed to the U.S. Supreme Court.
    • June 23, 2021: The Arizona Supreme Court denied Cruz's motion for reconsideration.
    • June 4, 2021: The Arizona Supreme Court denied Cruz's petition for postconviction relief.

    Background

    John Montenegro Cruz, the petitioner, was convicted of capital murder and sentenced to death in Arizona in 2005. Cruz was allegedly unable to inform the jury that he was unlikely to pose a danger in prison and would not be eligible for parole if spared the death penalty. In his petition before the U.S. Supreme Court, Cruz argued that the jury was misled into believing he could be eligible for parole if he were not sentenced to death. As a result, he argues, the "refusal to allow evidence of parole-ineligibility contributed to the jury's decision to sentence Cruz to death." [4]

    Cruz appealed to the Arizona Supreme Court in 2008. The state supreme court rejected his argument. Cruz then appealed again, arguing the Arizona Supreme Court's ruling in 2008 violated U.S. Supreme Court precedent established by Lynch v. Arizona. Cruz argued that the precedent from Lynch applied retroactively. The court rejected Cruz's argument. After several appeals, the Arizona Supreme Court found that Cruz was not entitled to post-conviction relief.[4]

    Simmons v. South Carolina (1994)

    In Simmons v. South Carolina, the U.S. Supreme Court ruled that a defendant facing the death penalty is entitled under due process to inform the jury that he or she will not be eligible for parole if sentenced to life in prison. Chief Justice William Rehnquist and Justices Sandra Day O'Connor, Anthony Kennedy wrote in a concurring opinion in Simmons: "[W]here the State puts the defendant’s future dangerousness in issue, and the only available alternative sentence to death is life imprisonment without possibility of parole, due process entitles the defendant to inform the capital sentencing jury—by either argument or instruction—that he is parole ineligible."[4]

    Lynch v. Arizona (2016)

    The U.S. Supreme Court overturned an Arizona Supreme Court ruling in which the state court had not considered Simmons was applicable to Arizona law. According to the U.S. Supreme Court opinion, "The Arizona Supreme Court thought Arizona's sentencing law sufficiently different from the others this Court had considered that Simmons did not apply. ... That conclusion conflicts with this Court's precedents."[5]

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions presented:
    “ Whether the Arizona Supreme Court’s holding that Arizona Rule of Criminal Procedure 32.1(g) precluded post-conviction relief is an adequate and independent state-law ground for the judgment.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]

    Outcome

    The court ruled to vacate and remand the decision of the Arizona Supreme Court in a 5-4 ruling. According to the Arizona Rule of Criminal Procedure 32.1(g), petitioners can challenge their sentences if "there has been a significant change in the law that, if applicable to the defendant’s case, would probably overturn the defendant’s judgment or sentence."[9] Referencing Lynch v. Arizona, Cruz appealed his sentencing to the Arizona Supreme Court, arguing that Lynch v. Arizona created a significant change in the law. The Arizona Supreme Court disagreed and found that Cruz was not entitled to post-conviction relief.

    If a case originated from a state court, the Supreme Court usually will not make rulings on questions of federal law if the state court's decision can be supported by an "adequate and independent state-law ground for the judgment."[3][10] In Cruz v. Arizona, the state of Arizona argued that the Arizona Supreme Court’s decision to deny Cruz post-conviction relief constituted as an adequate and independent state-law ground for the judgment. The Supreme Court rejected this argument. The Court's decision invalidated Arizona’s ruling denying Cruz post-conviction relief and allows Cruz to receive a new sentencing hearing where he will be able to inform the jury that if he were given a sentence of life in prison, he would be ineligible for parole.[10]

    Justice Sonia Sotomayor delivered the majority opinion of the court. Justice Amy Coney Barrett filed a dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Neil Gorsuch.[1][2]

    Opinion

    “ In exceptional cases where a state-court judgment rests

    on a novel and unforeseeable state-court procedural decision lacking fair or substantial support in prior state law, that decision is not adequate to preclude review of a federal question. The Arizona Supreme Court applied Rule 32.1(g) in a manner that abruptly departed from and directly conflicted with its prior interpretations of that Rule. Accordingly, the judgment of the Supreme Court of Arizona is vacated, and the case is remanded for further proceedings not inconsistent with this opinion[6]

    		”
    —Justice Sonia Sotomayor [11]

    Dissenting opinion

    “ The Court makes a case for why the Arizona Supreme

    Court’s interpretation of its own precedent is wrong. If I were on the Arizona Supreme Court, I might agree. But that call is not within our bailiwick. Our job is to determine whether the Arizona Supreme Court’s decision is defensible, and we owe the utmost deference to the state court in making that judgment. Cases of inadequacy are extremely rare, and this is not one. I respectfully dissent. [6]

    		”
    —Justice Amy Coney Barrett[12]

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[13]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 U.S. Supreme Court, Cruz v. Arizona - "Certiorari to the Supreme Court Of Arizona," accessed February 23, 2023
    2. ↑ 2.0 2.1 SCOTUSblog, Cruz v. Arizona accessed February 23, 2023
    3. ↑ 3.0 3.1 3.2 Supreme Court of the United States, Cruz v. Arizona - "Questions presented," accessed March 28, 2022
    4. ↑ 4.0 4.1 4.2 Supreme Court of the United States, Cruz v. Arizona - "Petition for a writ of certiorari," accessed March 28, 2022
    5. ↑ Supreme Court of the United States, Lynch v. Arizona - "Opinion," May 31, 2016
    6. ↑ 6.0 6.1 6.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ [Oral argument audio page https://www.supremecourt.gov/oral_arguments/audio/2022/21-846 Supreme Court of the United States, "Oral Argument - Audio," argued November 1, 2022]
    8. ↑ [URL Supreme Court of the United States, "Oral Argument - Transcript," argued DATE]
    9. ↑ Casetext, Ariz. R. Crim. P. 32.1, accessed February 27, 2023
    10. ↑ 10.0 10.1 Scotusblog, In rare win for people on death row, justices chide Arizona for ignoring Supreme Court precedent accessed February 27, 2023
    11. ↑ U.S. Supreme Court, Cruz v. Arizona - "Certiorari to the Supreme Court Of Arizona," accessed February 23, 2023
    12. ↑ U.S. Supreme Court, Cruz v. Arizona - "Certiorari to the Supreme Court Of Arizona," accessed February 23, 2023
    13. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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