In 'Extremely Rare' Ruling, SCOTUS Orders Resentencing of Arizona Prisoner
The state of Arizona has for two decades ignored a previous Supreme Court ruling that aimed to ensure defendants would be sentenced fairly.
The U.S. Supreme Court on Wednesday issued a rare rebuke of Arizona's criminal justice system as the majority ruled in favor of a death row inmate who has called for a resentencing, saying the state ignored legal precedents during his trial.
In a 5-4 decision, Chief Justice John Roberts and Justice Brett Kavanaugh joined with the court's three liberal judges in Cruz v. Arizona, with Justice Sonia Sotomayor writing the majority opinion.
The majority ruled that lawyers who prosecuted John Montenegro Cruz for the murder of a police officer in 2003 failed to inform jurors during his sentencing that if Cruz was not executed by the state, he would be sentenced to life in prison without the possibility of parole.
Instead, the prosecutors falsely told the jury that Cruz would be able to walk free unless he was sentenced to death.
As the Associated Press reported, at least one juror said after the trial that if she had been informed that Cruz would be sentenced to life in prison without parole, she "would have voted for that option."
Cruz is not the only Arizona death row inmate whose life could be spared by the ruling. For nearly two decades, the state has ignored a previous Supreme Court ruling that required jurors in certain death penalty cases to be informed that the alternative to capital punishment is a life sentence without parole.
Wednesday's ruling could overturn the death row sentences of roughly 30 inmates in Arizona, including Cruz, who may be granted new penalty phases of their trials.
Supreme Court observers including Mark Joseph Stern at Slate and Steve Vladeck of the University of Texas noted that post-conviction relief for an inmate is "rare" at the high court.
\u201cOh wow: The Supreme Court's third and final opinion of the day is in Cruz v. Arizona, and it's a 5\u20134 win for a prisoner seeking postconviction relief. Extremely rare these days. Roberts and Kavanaugh joined the liberals, with Sotomayor writing. https://t.co/VQL01Jk2Fp\u201d— Mark Joseph Stern (@Mark Joseph Stern) 1677078166
By allowing jurors to go uninformed of the option of a life sentence without parole, the majority said, Arizona violated the 1994 Supreme Court case Simmons v. South Carolina. In that case the court said prosecutors cannot tell jurors that a defendant will pose a threat to society if they're not actually eligible for parole.
Arizona did not apply that ruling to its death penalty cases, and Cruz's lawyers argued the state continued to ignore the ruling even after the court directly told officials to comply with Simmons in another 2016 ruling in the case Lynch v. Arizona.
"Arizona courts refused to apply the Supreme Court's decision in Lynch to cases that had already been decided," University of Michigan law professor Leah Litman explained at Slate. "They refused to apply Lynch on the grounds that state law allowed defendants to challenge their convictions or sentences on the basis of 'new' Supreme Court rules. And, Arizona continued, Lynch did not announce a 'new' rule. Lynch had simply applied an existing rule (from Simmons) to Arizona without actually changing the law in the process."
"Arizona's position would have effectively left Arizona defendants with no remedy at all," Litman continued.
Justice Elena Kagan expressed bewilderment at Arizona's position when the case was argued:
Cruz loses his Simmons claims on direct appeal because the Arizona courts say point-blank Simmons has never applied in Arizona. And then he loses the next time around because the Arizona courts say Simmons always applied... I mean, tails you win, heads I lose, whatever that expression is?
Litman noted that the Supreme Court has recently ruled in favor of states that want permission to ignore rulings that officials oppose.
"It's basically what the Supreme Court allowed Texas to get away with on abortion in the S.B. 8 case before the courtultimately overruledRoe v. Wade last term," wrote Litman. "In 2021, the Texas Legislature adopted S.B. 8, a novel abortion restriction that was designed to shut down abortion access without allowing abortion providers to challenge the law in court. In the case challenging S.B. 8,five justices (the five justices who would later overrule Roe) let Texas get away with that gambit while Roe was still standing. The five justices allowed Texas to effectively nullify a Supreme Court decision that Texas didn't care for, and that six justices on the court didn't care for either."
"Had the court allowed Arizona to do the same in Cruz v. Arizona," she added, "it would have facilitated even more legal machinations that deprive people of their constitutional rights."