Cruz v. Arizona
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Cruz v. Arizona and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Cruz v. Arizona.
John Montenegro Cruz was convicted of capital murder and sentenced to death in Arizona. He argued that under Simmons v. South Carolina, he should have informed the jury that a life sentence would be without parole. The U.S. Supreme Court found the Arizona Supreme Court's interpretation of procedural rules inadequate, allowing federal review.
Holding
The single most important “bottom line” of what the Court decided in Cruz v. Arizona.
The Court held that the Arizona Supreme Court's decision was an exceptional case where the state-court judgment was inadequate to foreclose review of the federal claim.
Constitutional Concepts
These are the Constitution-related themes that appear in Cruz v. Arizona. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Cruz v. Arizona
The case involves whether the Arizona Supreme Court's interpretation of a procedural rule was adequate to preclude federal review, implicating procedural due process concerns.
Syllabus excerpt (verbatim)This case is an exception, however, implicating this Court's rule that 'an unforeseeable and unsupported state-court decision on a question of state procedure does not constitute an adequate ground to preclude this Court's review of a federal question.'
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Why Judicial Review is relevant to Cruz v. Arizona
The Court's decision involves its power to review state court judgments that rest on inadequate state procedural grounds.
Syllabus excerpt (verbatim)Given the Court's conclusion that the Arizona Supreme Court's application of Rule 32.1(g) to Lynch is so novel and unfounded that it does not constitute an adequate state procedural ground...
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Why Substantive Due Process is relevant to Cruz v. Arizona
The case touches on the substantive rights of capital defendants to have significant changes in law considered in their cases.
Syllabus excerpt (verbatim)Arizona's interpretation generates a catch-22 for Cruz and other similarly situated capital defendants that only serves to compound its novelty.
Key Quotes
Short excerpts from the syllabus in Cruz v. Arizona that support the summary and concepts above.
The Arizona Supreme Court's holding that Lynch was not a significant change in the law is an exceptional case.
A state procedural ruling that is 'firmly established and regularly followed' will ordinarily 'be adequate to foreclose review of a federal claim.'
This interpretation of Rule 32.1(g) is entirely new and conflicts with prior Arizona case law.
