Mendoza-Martinez factors (Arizona) · Go Syfert
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Mendoza-Martinez factors in Arizona

8 Arizona opinions name it 2 courts 1991–2020 0 in the last five years

The cases below were cited by Arizona courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Kennedy v. Mendoza-Martinezgreen
scotus · 1963 · cited in 4 Arizona opinions naming this issue, 1992–2018
2 sentences

2018After finding "[t]he legislative history behind § 13-3821 does not indicate whether the statute was intended to be punitive or regulatory," the court applied the Mendoza-Martinez 2 factors, which include, among other things, " 'whether [the sanction] has historically been regarded as a punishment' " and " 'whether its operation will promote the traditional aims of punishment-retribution and deterrence.' " Id. (quoting Kennedy v. Mendoza-Martinez , 372 U.S. 144 , 168-69, 83 S.Ct. 554 , 9 L.Ed.2d 644 (1963) ). ¶13 In balancing the Mendoza-Martinez factors, the supreme court determined § 13-3821"

2018After finding "[t]he legislative history behind § 13-3821 does not indicate whether the statute was intended to be punitive or regulatory," the court applied the Mendoza-Martinez 2 factors, which include, among other things, " 'whether [the sanction] has historically been regarded as a punishment' " and " 'whether its operation will promote the traditional aims of punishment-retribution and deterrence.' " Id. (quoting Kennedy v. Mendoza-Martinez , 372 U.S. 144 , 168-69, 83 S.Ct. 554 , 9 L.Ed.2d 644 (1963) ). ¶13 In balancing the Mendoza-Martinez factors, the supreme court determined § 13-3821"

24
Smith v. Doegreen
scotus · 2003 · cited in 2 Arizona opinions naming this issue, 2010–2010
2 sentences

2010See Smith, 538 U.S. at 97 , 123 S.Ct. 1140 (Mendoza-Martinez factors provide “useful framework” but are “‘neither exhaustive nor dispositive’” when determining if statute punitive), quoting Ward, 448 U.S. at 249 , 100 S.Ct. 2636 .

2010See Smith, 538 U.S. at 97 , 123 S.Ct. 1140 (Mendoza-Martinez factors provide “useful framework” but are “‘neither exhaustive nor dispositive’” when determining if statute punitive), quoting Ward, 448 U.S. at 249 , 100 S.Ct. 2636 .

22
United States v. Wardgreen
scotus · 1980 · cited in 2 Arizona opinions naming this issue, 2010–2010
2 sentences

2010See Smith, 538 U.S. at 97 , 123 S.Ct. 1140 (Mendoza-Martinez factors provide “useful framework” but are “‘neither exhaustive nor dispositive’” when determining if statute punitive), quoting Ward, 448 U.S. at 249 , 100 S.Ct. 2636 .

2010See Smith, 538 U.S. at 97 , 123 S.Ct. 1140 (Mendoza-Martinez factors provide “useful framework” but are “‘neither exhaustive nor dispositive’” when determining if statute punitive), quoting Ward, 448 U.S. at 249 , 100 S.Ct. 2636 .

22
United States v. Haymondgreen
· 2019 · cited in 1 Arizona opinions naming this issue, 2020–2020
2 sentences

2020See, e.g., Haymond, 139 S. Ct. at 2378 .

2020See, e.g., Haymond, 139 S. Ct. at 2378 .

11
Thomas F. Worthy v. The City of Phenix City, Alabamagreen
ca11 · 2019 · cited in 1 Arizona opinions naming this issue, 2020–2020
2 sentences

2020Indeed, another case cited by the majority, supra ¶ 84, makes the line of demarcation clear, applying the Mendoza-Martinez factors in the context of a red-light running violation, noting that the Sixth Amendment right to jury trial right is “only guaranteed during a criminal prosecution,” whereas in that case the appellants had not “alleged that there was even a remote threat of future criminal prosecution.” Worthy v. City of Phenix City, Ala., 930 F.3d 1206, 1220 (11th Cir. 2019).

2020Indeed, another case cited by the majority, supra ¶ 84, makes the line of demarcation clear, applying the Mendoza-Martinez factors in the context of a red-light running violation, noting that the Sixth Amendment right to jury trial right is “only guaranteed during a criminal prosecution,” whereas in that case the appellants had not “alleged that there was even a remote threat of future criminal prosecution.” Worthy v. City of Phenix City, Ala., 930 F.3d 1206, 1220 (11th Cir. 2019).

11
In Re Reedgreen
cal · 1983 · cited in 1 Arizona opinions naming this issue, 1992–1992
2 sentences

1992See In re Reed, 33 Cal.3d 914, 920-23 , 663 P.2d 216, 218-20 , 191 Cal.Rptr. 658, 660-62 (1983) (applying Mendoza-Martinez factors in determining that sex offender registration is cruel and unusual punishment). 8 .

1992See In re Reed, 33 Cal.3d 914, 920-23 , 663 P.2d 216, 218-20 , 191 Cal.Rptr. 658, 660-62 (1983) (applying Mendoza-Martinez factors in determining that sex offender registration is cruel and unusual punishment). 8 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
State v. Noble green
ariz · 1992
2 sentences

2010When Noble examined the sex offender registration system in effect nearly eighteen years ago to determine whether § 13-3821 constituted an impermissible ex post facto law, our state supreme court noted, after balancing the Mendoza-Martinez factors, that its “decision [wa]s close.” 171 Ariz. at 178 , 829 P.2d at 1224 .

2010When Noble examined the sex offender registration system in effect nearly eighteen years ago to determine whether § 13-3821 constituted an impermissible ex post facto law, our state supreme court noted, after balancing the Mendoza-Martinez factors, that its “decision [wa]s close.” 171 Ariz. at 178 , 829 P.2d at 1224 .

31996–2010
People v. Adams green
illappct · 1990
2 sentences

1991In People v. Adams , the Illinois Court of Appeals, which declined to apply the Mendoza-Martinez analysis, held that Illinois' sex offender registration statute was not punishment. 144 Ill.Dec. 402, 406 , 555 N.E.2d 761, 765 , appeal allowed, 133 Ill.2d 560 , 149 Ill.Dec. 325 , 561 N.E.2d 695 (1990).

1991In People v. Adams , the Illinois Court of Appeals, which declined to apply the Mendoza-Martinez analysis, held that Illinois' sex offender registration statute was not punishment. 144 Ill.Dec. 402, 406 , 555 N.E.2d 761, 765 , appeal allowed, 133 Ill.2d 560 , 149 Ill.Dec. 325 , 561 N.E.2d 695 (1990).

11991–1991

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 13-3821 (8) AZ § Ariz. Rev. Stat. § 13-3825 (4) AZ § Ariz. Rev. Stat. § 41-1750 (4) AZ § Ariz. Rev. Stat. § 13-1404 (3) AZ § Ariz. Rev. Stat. § 13-3822 (3) AZ § Ariz. Rev. Stat. § 13-3824 (3) AZ § Ariz. Rev. Stat. § 13-3826 (3) AZ § Ariz. Rev. Stat. § 13-3827 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 65 (2003–2026) IL 19 (1992–2021) CA 17 (1999–2021) MI 16 (2014–2026) AZ 8 (1991–2020) IN 8 (2009–2019) WI 7 (2002–2021) ME 7 (2001–2015) CO 6 (2009–2026) KS 6 (1996–2017) IA 6 (1997–2021) MD 6 (1998–2020) NM 6 (2003–2015) NC 6 (2007–2010) WA 5 (1994–2023) OR 5 (1977–2024) NJ 4 (1995–2014) ND 4 (1999–1999) OH 4 (1998–2008) LA 3 (1987–2025) NY 3 (1988–2010) DC 2 (2004–2004) WV 2 (1992–2020) MN 2 (2014–2017) MA 2 (1996–2009) SC 2 (2013–2014) KY 2 (2010–2010) OK 2 (2013–2025) GA 2 (2018–2018) AL 2 (2004–2011) MT 2 (2003–2005) NV 2 (2013–2013) MS 2 (2005–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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