Cruz v. Arizona: Arizona rule was not “adequate” state grounds to bar federal review of capital defendant’s claim he wasn’t allowed to tell jury he wouldn’t be paroled
An Arizona postconviction rule was not an “adequate” state ground to bar federal review and relief on a claim by a capital defendant that he wasn’t allowed to inform his jury that he would not be eligible for release, the U.S. Supreme Court held February 22 in Cruz v. Arizona.
John Montenegro Cruz was convicted of murder and sentenced to death. On direct appeal, he argued his death sentence violated Simmons v. South Carolina, 512 U.S. 154 (1994), because he wasn’t allowed to inform the jury that a life sentence would be without parole.
After the Arizona courts rejected Cruz’s claims, and similar claims by other defendants, the U.S. Supreme Court summarily held, in Lynch v. Arizona, 578 U.S. 613 (2016), that it was fundamental error to conclude that Simmons“did not apply” in Arizona.
Cruz then brought a new postconviction action under an Arizona rule that permits a successive petition if there has been a significant change in the law.
The Arizona courts denied relief on grounds that Lynch was not a “significant change in the law.”
The Supreme Court reversed, in a 5-4 opinion.
The question before the Court was whether Arizona’s postconviction rule was an “adequate and independent” state law ground for the judgment.
A federal court cannot review a question of federal law if the decision of the state court rests on a state law ground that is “independent” of the federal question and “adequate” to support the judgment.
This case turns on “adequacy”, the Court said.
Usually, a violation of a state procedural rule that is “firmly established and regularly followed” will be “adequate” to foreclose federal review, the Court said.
But in “exceptional” and “the rarest” cases, a generally sound state rule may be applied in a manner that renders the state grounds “inadequate” to stop federal review.
“Novelty in procedural requirements cannot be permitted to thwart review in this Court applied for by those who, in justified reliance upon prior decisions, seek vindication in state courts of their federal constitutional rights”, the Court said.
After Lynch, Arizona courts had recognized that capital defendants have a due process right to provide a jury with information that a life sentence would be without parole, the Court said. “It is hard to imagine a clearer break from the past.”
Yet Arizona courts continued to hold that Lynch was not “a significant change in the law”, the Court said.
Arizona’s interpretation of its postconviction rule to reach this result was “entirely new and in conflict with prior Arizona case law”, the Court said. “What makes the interpretation so novel is the way in which it disregards the effect of Lynch on the law in Arizona.”
Under the “unusual circumstances” here, Arizona’s application of its postconviction rule “was so novel and unfounded that it does not constitute an adequate state procedural ground”, the Court held. “It is therefore not necessary to reach the further issue whether the decision below is independent of federal law.”
Justice Barrett dissented, joined by Justices Thomas, Alito and Gorsuch.
The adequate and independent state grounds doctrine is based on two features of the Court’s jurisdiction, Barrett said.
“First, this Court is powerless to revise a state court’s interpretation of its own law”, she said. “We thus cannot disturb state-court rulings on state-law questions that are independent of federal law.”
“Second, Article III empowers federal courts to render judgments, not advisory opinions”, she said. “So if an independent state ground of decision is adequate to sustain the judgment, we lack jurisdiction over the entire dispute.”
A state ground should be found inadequate “only by a decision so blatantly disingenuous that it reveals hostility to federal rights or those asserting them”, Barrett said.
Here, Arizona “did not contradict its own settled law”, Barrett said. “Instead, it confronted a new question and gave an answer reasonably consistent with its precedent.”
“Our job is to determine whether the Arizona Supreme Court’s decision is defensible, and we owe the utmost deference to the state court in making that judgment”, she concluded. “Cases of inadequacy are extremely rare, and this is not one.”