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John Montenegro Cruz v. Arizona

Paid petition · Supreme Court of Arizona, No. CR-17-0567-PC · judgment June 4, 2021


Decided · February 22, 2023
Pre-decision estimate: 8% cert probability (95% interval 5%–11%)

Before the decision, about 1.9× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a circuit split argued in the petition, and a dissent in the court below (flagged in the petition), and down for a state or local-government respondent.

Question presented

In Simmons v. South Carolina, 512 U.S. 154 (1994), this Court held that in cases where a capital defendant's future dangerousness is at issue, due process entitles the defendant to inform the jury that he will be ineligible for parole if not sentenced to death. For many years thereafter, the Arizona Supreme Court refused to apply Simmons. In Lynch v. Arizona, 578 U.S. 613 (2016) (per curiam), this Court summarily reversed the Arizona Supreme Court's misapplication of Simmons and confirmed that the Simmons rule applies in Arizona. This petition is brought by a capital defendant in Arizona whose conviction became final after Simmons but before Lynch. He was sentenced to death after the trial judge repeatedly denied him his right under Simmons to inform the jury that he was parole-ineligible. After this Court in Lynch applied Simmons to Arizona, he sought postconviction relief in state court seeking the relief that Simmons and Lynch require. The Arizona Supreme Court denied his claim. Although Arizona provides a forum for federal constitutional claims on collateral review, and although the Arizona Supreme Court recognized that Lynch "was dictated by" Simmons, the court concluded that the rule of Lynch should not apply to cases pending on collateral review. This petition presents the question whether this Court's decision in Lynch applied a settled rule of federal law that must be applied to cases pending on collateral review in Arizona. GRANTED LIMITED TO THE FOLLOWING QUESTION: 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.

Counsel of record

For petitioner
Neal Kumar Katyal
Hogan Lovells US LLP

For respondent
Jeffrey Lee Sparks
Arizona Attorney General

Case

Conference history
Distributed for 2 conferences

Amicus briefs
2 cert-stage · 6 merits
(5 supporting pet./neither, 1 respondent)

Argument & decision

Argued November 1, 2022 — Neal K. Katyal · Joseph A. Kanefield. Audio and transcript

Decided February 22, 2023. Opinion by Sotomayor.

Proceedings

  1. Apr 26 2023
    Record returned to the Superior Court of the State of Arizona (Pima County) 1 Box.
  2. Apr 25 2023
    Record returned to the Supreme Court of Arizona (3 boxes and the electronic record).
  3. Mar 27 2023
    Judgment and mandate issued.
  4. Feb 22 2023
    Judgment VACATED and case REMANDED. Sotomayor, J., delivered the opinion of the Court, in which Roberts, C. J., and Kagan, Kavanaugh, and Jackson, JJ., joined. Barrett, J., filed a dissenting opinion, in which Thomas, Alito, and Gorsuch, JJ., joined.
  5. Dec 07 2022
    Record received from the Supreme Court of Arizona (3 boxes and the electronic record).
  6. Nov 01 2022
    Argued. For petitioner: Neal K. Katyal, Washington, D. C. For respondent: Joseph A. Kanefield, Chief Deputy Attorney General, Phoenix, Ariz.
  7. Oct 11 2022
    Record received from the Superior Court of the State of Arizona (Pima County) 1 Box. Part of the record has been electronically filed.
  8. Sep 12 2022
    Record requested from the Supreme Court of Arizona.
  9. Sep 12 2022
    Reply of petitioner John Montenegro Cruz filed. (Distributed)
  10. Aug 31 2022
    CIRCULATED
  11. Aug 19 2022
    Brief amici curiae of Jonathan F. Mitchell, et al. filed.
  12. Aug 12 2022
  13. Aug 03 2022
    ARGUMENT SET FOR Tuesday, November 1, 2022.
  14. Jun 21 2022
    Amicus brief of Habeas Scholars not accepted for filing. (June 22, 2022)
  15. Jun 21 2022
    Brief amici curiae of Ohio Justice & Policy Center and Roderick & Solange MacArthur Justice Center filed.
  16. Jun 21 2022
    Brief amici curiae of Federal Courts Scholars filed.
  17. Jun 21 2022
    Brief amici curiae of LatinoJustice PRLDEF, et al. filed.
  18. Jun 21 2022
    Brief amici curiae of Arizona Capital Representation Project, et al. filed.
  19. Jun 21 2022
    Brief amici curiae of National Association of Criminal Defense Lawyers, et al. filed.
  20. Jun 13 2022
    Blanket Consent filed by Respondent, Arizona
  21. Jun 13 2022
    Brief of petitioner John Montenegro Cruz filed.
  22. Jun 13 2022
    Joint appendix filed. (Statement of costs filed)
  23. Jun 06 2022
    Blanket Consent filed by Petitioner, John Montenegro Cruz
  24. Apr 28 2022
    Motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioner's brief on the merits is extended to and including June 13, 2022. The time to file respondent's brief on the merits is extended to and including August 12, 2022.
  25. Apr 07 2022
    Motion for an extension of time to file the briefs on the merits filed.
  26. Mar 28 2022
    Petition GRANTED limited to the following question: 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.
  27. Mar 21 2022
    DISTRIBUTED for Conference of 3/25/2022.
  28. Feb 23 2022
    DISTRIBUTED for Conference of 3/18/2022.
  29. Feb 22 2022
    Reply of petitioner John Montenegro Cruz filed. (Distributed)
  30. Feb 04 2022
    Brief of respondent Arizona in opposition filed.
  31. Jan 06 2022
    Amicus brief of LatinoJustice PRLDEF not accepted for filing. (January 07, 2022 - correct pdf to be re-efiled)
  32. Jan 06 2022
    Brief amicus curiae of LatinoJustice PRLDEF filed.
  33. Jan 06 2022
    Brief amici curiae of Habeas Scholars filed.
  34. Dec 21 2021
    Motion to extend the time to file a response is granted and the time is extended to and including February 7, 2022.
  35. Dec 20 2021
    Motion to extend the time to file a response from January 6, 2022 to February 7, 2022, submitted to The Clerk.
  36. Dec 16 2021
    Waiver of Arizona filed 12/16/21 removed from docket. (See Rule 15.1)
  37. Nov 22 2021
    Petition for a writ of certiorari filed. (Response due January 6, 2022)