SCOTUSblog by Alexis Hoag-Fordjour 2/23/2023
In what was only the second opinion day of the 2022-23 term, the Supreme Court delivered a rare win for a criminally convicted petitioner and offered a clarifying example of when it is appropriate for a federal court to intervene when a state court fails to apply federal law. In a 5-4 decision in Cruz v. Arizona, the court ruled in favor of John Montenegro Cruz, a man on death row in Arizona. Cruz and about 30 other similarly situated individuals will be entitled to new sentencing hearings as a result of the court’s ruling.
Justice Sonia Sotomayor authored the opinion, with Chief Justice John Roberts and Justices Elena Kagan, Brett Kavanaugh, and Ketanji Brown Jackson signing on.
As background, in 2005, a Pima County jury convicted Cruz of first-degree capital murder for the death of a police officer. The jury was then tasked with determining the appropriate sentence. According to Arizona law, capital defendants who committed crimes after 1993, like Cruz, were (and remain) ineligible for parole. Thus, the only possible sentences for the jury to choose from were life in prison or death. Throughout the trial, Cruz repeatedly sought to inform the jury that if they declined to sentence him to death, he would be ineligible for parole. The trial judge refused. This was no insignificant detail. A decade earlier, in Simmons v. South Carolina, the Supreme Court held that capital defendants have a constitutional right to inform the jury that they would not be eligible for parole if the jury returned a life sentence.
Instead, the Arizona judge instructed the jury that Cruz was eligible for three possible sentences: (1) death, (2) life without the possibility of parole, or (3) life with a possibility of parole after 25 years. This was not only inaccurate, it also proved lethal. The jury sentenced Cruz to death, believing that if they declined to do so, the judge would choose between the two remaining sentences. The court’s opinion notes that multiple jurors spoke to the media immediately following Cruz’s trial, describing the decision as tearful for all involved and “gut-wrenching.” The jurors expressed a desire to “have voted for life without the possibility of parole, but” lamented that “they were not given that option.”
More:
https://www.scotusblog.com/2023/02/in-rare-win-for-people-on-death-row-justices-chide-arizona-for-ignoring-supreme-court-precedent/
