Cruz v. Arizona (Cruz v Arizona)

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2023 United States Supreme Court case

Cruz v. Arizona, 598 U.S. 17 (2023), was a United States Supreme Court case related to claim preclusion in _habeas corpus _.

Background

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In 2003, John Montenegro Cruz shot and killed Tucson, Arizona police officer Patrick Hardesty. He was convicted of capital murder and sentenced to death in state court in 2005. He argued at trial and on direct appeal that under _Simmons v. South Carolina _, the jury should have been told that a life sentence in Arizona would not allow for parole, but the state courts rejected this claim, holding that Simmons did not apply to Arizona’s sentencing scheme.

After Cruz’s conviction became final, the Supreme Court held in _Lynch v. Arizona _ that it was error to conclude that Simmons did not require juries be offered such instructions in the state. Cruz then sought postconviction relief under Arizona Rule of Criminal Procedure 32.1(g), but the Arizona Supreme Court denied relief in 2021.

Cruz filed a petition for a writ of certiorari, asking whether Lynch applies to cases pending on collateral review.

Supreme Court of the United States

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The Supreme Court granted certiorari on March 28, 2022, limited to the question of whether the judgment of the Arizona Supreme Court rested on an adequate and independent state-law ground . On February 22, 2023, the Court in a decision by Justice Sonia Sotomayor reversed the decision of the Arizona Supreme Court.

The Supreme Court generally does not review if a state court’s decision rests on a state-law ground that is independent of the federal issue and adequate to support the judgment, as explained in _Lee v. Kemna _ (2002). However, in exceptional cases, a state procedural rule applied in an unforeseeable or unsupported manner does not constitute an adequate ground to foreclose review of a federal claim. This principle has been applied for over a century and reaffirmed in later decisions such as _NAACP v. Alabama ex rel. Patterson _ (1958) and _Walker v. Martin _ (2011), which emphasized that novel, arbitrary, or unsupported procedural requirements cannot be used to block review of federal constitutional rights.

The Arizona Supreme Court’s refusal to treat Lynch as a “significant change in the law” under Rule 32.1(g) was a novel and unsupported application of state procedure that ignored its effect on Arizona law, rendering the state procedural ground inadequate to bar federal review.