Facts of the Case
In 2005, a jury convicted John Montenegro Cruz of first-degree murder for the 2003 killing of a Tucson police officer and sentenced Cruz to death. The Arizona Supreme Court affirmed Cruz’s conviction and sentence, and the U.S. Supreme Court denied his petition for a writ of certiorari.
In 2012, Cruz filed a petition in state court for post-conviction relief, which the court dismissed, and the Arizona Supreme Court denied review.
In 2014, Cruz initiated federal habeas proceedings. In 2016, while those proceedings were ongoing, the U.S. Supreme Court decided Lynch v. Arizona (Lynch II), holding that the Arizona Supreme Court had misapplied precedent. Cruz then filed a second petition for post-conviction relief. Ordinarily that second petition would be barred, but state law provides for an exception if there was an intervening “significant change in the the law.” Cruz argued that the decision in Lynch II was a signficant change in the law, that it applies retroactively, and would probably overturn his sentence.
The Arizona Supreme Court concluded that Lynch II was not a significant change in the law and was instead based on precedent well established at the time the defendant was convicted and sentenced.
Questions
Is the Arizona Supreme Court’s ruling that a state rule of criminal procedure precluded post-conviction relief an adequate and independent state-law ground for the judgment against him, thereby precluding review by a federal court?
Conclusions
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The Arizona Supreme Court’s holding below is not an adequate state-law ground supporting that judgment and thus does not preclude federal court review. Justice Sonia Sotomayor authored the 5-4 majority opinion of the Court.
If the judgment of a state court rests on “adequate and independent state-law grounds,” the Supreme Court will not decide a simultaneously presented question of federal law. Generally, a state’s procedural ruling is adequate to foreclose a review of a federal claim.
The Arizona Supreme Court’s decision holding that Lynch v. Arizona, 578 U.S. 613, did not represent a “significant change in the law,” as it was entirely new and conflicted with existing state law. Because the interpretation was so novel and unforeseeable, it cannot constitute an adequate state procedural ground.
Justice Amy Coney Barrett authored a dissenting opinion, in which Justices Clarence Thomas, Samuel Alito, and Neil Gorsuch joined, arguing that the Court should have given the “utmost deference” to the state court’s interpretation of its own precedent and that it failed to do so.
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