Cruz v. Arizona

Supreme Court of the United States · 2023 · Federal Courts

Federal Courtsadequate and independent state groundsstate procedural adequacypostconviction reviewadequate and independent state groundsadequacystate procedural defaultnovel and unforeseeable state rule

Facts

At trial and on direct appeal, Cruz argued under Simmons that he should be allowed to tell the jury that a life sentence in Arizona would be without parole, but Arizona courts rejected that argument based on then-binding Arizona precedent. After Cruz's conviction became final, the Supreme Court in Lynch summarily reversed Arizona and held it was fundamental error to conclude that Simmons did not apply in Arizona. Cruz then sought postconviction relief under Arizona Rule 32.1(g), which permits a successive petition when there has been a significant change in the law that would probably overturn the judgment or sentence. The Arizona Supreme Court held that Lynch was not a significant change in the law because Simmons had already been clearly established federal law at the time of Cruz's trial.

Issue

Whether the Arizona Supreme Court's ruling that Lynch was not a "significant change in the law" under Rule 32.1(g) constituted an adequate state-law ground that foreclosed Supreme Court review of Cruz's federal claim.

Rule

Ordinarily, a firmly established and regularly followed state procedural rule is adequate to bar review of a federal claim. But in the rare exceptional case, an unforeseeable and unsupported state-court decision on a question of state procedure is not an adequate state ground; a state court may not foreclose federal review by adopting a novel and unforeseeable interpretation of its procedural rule that lacks fair or substantial support in prior state law.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, the state supreme court has long described the overruling of previously binding precedent as the classic example of a "significant change in the law" under its postconviction rule. After the U.S. Supreme Court summarily reverses an Ohio line of cases on a federal constitutional issue, the Ohio Supreme Court denies a successive petition by announcing for the first time that only changes in federal doctrine count, not changes in Ohio's application of federal law.

If the prisoner seeks U.S. Supreme Court review of the underlying federal claim, is the Ohio court's procedural ruling likely an adequate state ground?

Explanation. Ordinarily, a firmly established and regularly followed state procedural rule is adequate. But in the rare exceptional case, a state court's novel and unforeseeable procedural interpretation that lacks fair or substantial support in prior state law is not adequate. Here, the state court newly disregards the effect of the intervening decision on state law, even though prior state cases treated overruling binding precedent as the archetype of a significant change. That makes the ruling inadequate. (Derived from Cruz v. Arizona (n.d.).)