jury trial on aggravating factors (Arizona) · Go Syfert
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jury trial on aggravating factors in Arizona

7 Arizona opinions name it 2 courts 1994–2012 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 (11)

CaseFollowedCited
Blakely v. Washingtongreen
scotus · 2004 · cited in 2 Arizona opinions naming this issue, 2012–2012
2 sentences

2012And even after the United States Supreme Court ruled defendants have a right to have aggravating factors decided by a jury in Blakely v. Washington, 542 U.S. 296, 301, 303-04 , 124 S.Ct. 2531 , 159 L.Ed.2d 403 (2004), the legislature did not amend the statute to expressly limit diminished capacity evidence from being presented in a jury trial on aggravating factors.

2012And even after the United States Supreme Court ruled defendants have a right to have aggravating factors decided by a jury in Blakely v. Washington, 542 U.S. 296, 301, 303-04 , 124 S.Ct. 2531 , 159 L.Ed.2d 403 (2004), the legislature did not amend the statute to expressly limit diminished capacity evidence from being presented in a jury trial on aggravating factors.

22
State v. Garciagreen
arizctapp · 2011 · cited in 2 Arizona opinions naming this issue, 2012–2012
2 sentences

2012See State v. Garcia, 227 Ariz. 377, ¶ 15 , 258 P.3d 195, 198-99 (App.2011) (legislature “free to amend” statute to reflect its intent). ¶ 15 Thus, as demonstrated by the language of the statute and our supreme court’s interpretation of it, to the extent the evidence here constitutes evidence of diminished capacity, the legislature only intended to preclude such evidence when a defendant attempts to use it to negate his or her responsibility for a crime in the guilt/innocence phase of the trial.

2012See State v. Garcia, 227 Ariz. 377, ¶ 15 , 258 P.3d 195, 198-99 (App.2011) (legislature “free to amend” statute to reflect its intent). ¶ 15 Thus, as demonstrated by the language of the statute and our supreme court’s interpretation of it, to the extent the evidence here constitutes evidence of diminished capacity, the legislature only intended to preclude such evidence when a defendant attempts to use it to negate his or her responsibility for a crime in the guilt/innocence phase of the trial.

22
State v. Landrigangreen
ariz · 1993 · cited in 2 Arizona opinions naming this issue, 1994–1996
2 sentences

1996This argument was rejected in State v. Landrigan, 176 Ariz. 1, 6 , 859 P.2d 111, 116 , cert. denied, 510 U.S. 927 , 114 S.Ct. 334 , 126 L.Ed.2d 279 (1993).

1996This argument was rejected in State v. Landrigan, 176 Ariz. 1, 6 , 859 P.2d 111, 116 , cert. denied, 510 U.S. 927 , 114 S.Ct. 334 , 126 L.Ed.2d 279 (1993).

12
State v. Browngreen
ariz · 2006 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

11
State v. Offinggreen
ariz · 1976 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

11
State v. Wrengreen
arizctapp · 1977 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

11
State v. Porrasgreen
arizctapp · 1982 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

11
State v. Cochrangreen
ariz · 1973 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

11
State v. Mankelgreen
arizctapp · 1976 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

2007See State v. Brown, 212 Ariz. 225, 231, ¶¶ 26, 29 , 129 P.3d 947, 953 (2006) (remanding for a sentencing hearing because *123 defendant did not appropriately waive his right to a jury trial on aggravating factors); State v. Offing, 113 Ariz. 287, 288 , 551 P.2d 556, 557 (1976) (reversing and remanding for new trial because record did not affirmatively show that defendant knew he was giving up jury trial right); Cochran, 109 Ariz. at 328 , 509 P.2d at 221 (reversing and remanding for new trial based upon ineffective waiver by defense counsel); Smith, 197 Ariz. at 339, ¶ 18, 4 P.3d at 394 (rever

11
State v. Le Noblegreen
arizctapp · 2007 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007But see Ritchey, 107 Ariz. at 554 , 490 P.2d at 561 (remanded to the trial court for the purpose of determining whether the defendant had ratified the action of his attorney in waiving jury trial rights); Le Noble, 216 Ariz. at 185, ¶ 20 , 164 P.3d at 691 . 3 ¶ 22 Decisions from other jurisdictions also support our conclusion that Baker is entitled to a new trial.

2007But see Ritchey, 107 Ariz. at 554 , 490 P.2d at 561 (remanded to the trial court for the purpose of determining whether the defendant had ratified the action of his attorney in waiving jury trial rights); Le Noble, 216 Ariz. at 185, ¶ 20 , 164 P.3d at 691 . 3 ¶ 22 Decisions from other jurisdictions also support our conclusion that Baker is entitled to a new trial.

11
State v. Spencergreen
ariz · 1993 · cited in 1 Arizona opinions naming this issue, 1994–1994
2 sentences

1994No. See State v. Spencer, 176 Ariz. 36, 45 , 859 P.2d 146, 155 (1993) citing State v. Landrigan, 176 Ariz. 1, 6 , 859 P.2d 111, 116 (1993) (equal protection not violated because jury determines aggravating factors in non-capital cases whereas judge makes determination in capital cases). 12.

1994No. See State v. Spencer, 176 Ariz. 36, 45 , 859 P.2d 146, 155 (1993) citing State v. Landrigan, 176 Ariz. 1, 6 , 859 P.2d 111, 116 (1993) (equal protection not violated because jury determines aggravating factors in non-capital cases whereas judge makes determination in capital cases). 12.

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Ritcheygreen
ariz · 1971 · cited in 1 Arizona opinions naming this issue, 2007–2007
2 sentences

2007But see Ritchey, 107 Ariz. at 554 , 490 P.2d at 561 (remanded to the trial court for the purpose of determining whether the defendant had ratified the action of his attorney in waiving jury trial rights); Le Noble, 216 Ariz. at 185, ¶ 20 , 164 P.3d at 691 . 3 ¶ 22 Decisions from other jurisdictions also support our conclusion that Baker is entitled to a new trial.

2007But see Ritchey, 107 Ariz. at 554 , 490 P.2d at 561 (remanded to the trial court for the purpose of determining whether the defendant had ratified the action of his attorney in waiving jury trial rights); Le Noble, 216 Ariz. at 185, ¶ 20 , 164 P.3d at 691 . 3 ¶ 22 Decisions from other jurisdictions also support our conclusion that Baker is entitled to a new trial.

11

Also cited on this issue (3)

CaseCitedYears
State v. Ring green
ariz · 2003
2 sentences

2011State v. Ring, 204 Ariz. 534 , 65 P.3d 915 (2003).

2011State v. Ring, 204 Ariz. 534 , 65 P.3d 915 (2003).

12011–2011
United States v. Cotton green
scotus · 2002
2 sentences

2003Substantial differences exist between a defendant's decision to concede an aggravating circumstance and a defendant's decision not to contest an aggravating circumstance, and we distinguish between those situations. ¶ 92 In United States v. Cotton , the Supreme Court reviewed a case in which the defendant did not contest an element responsible for his sentence enhancement. 535 U.S. 625 , 122 S.Ct. 1781 , 152 L.Ed.2d 860 (2002).

2003Substantial differences exist between a defendant's decision to concede an aggravating circumstance and a defendant's decision not to contest an aggravating circumstance, and we distinguish between those situations. ¶ 92 In United States v. Cotton , the Supreme Court reviewed a case in which the defendant did not contest an element responsible for his sentence enhancement. 535 U.S. 625 , 122 S.Ct. 1781 , 152 L.Ed.2d 860 (2002).

12003–2003
Robles v. United States green
scotus · 1993
2 sentences

1996This argument was rejected in State v. Landrigan, 176 Ariz. 1, 6 , 859 P.2d 111, 116 , cert. denied, 510 U.S. 927 , 114 S.Ct. 334 , 126 L.Ed.2d 279 (1993).

1996This argument was rejected in State v. Landrigan, 176 Ariz. 1, 6 , 859 P.2d 111, 116 , cert. denied, 510 U.S. 927 , 114 S.Ct. 334 , 126 L.Ed.2d 279 (1993).

11996–1996

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-120.21 (3) AZ § Ariz. Rev. Stat. § 13-702 (3) AZ § Ariz. Rev. Stat. § 13-703 (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

CA 7 (2014–2026) AZ 7 (1994–2012) WA 5 (2005–2024) MN 2 (2006–2024) AK 2 (2009–2018)

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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