Cruz v. Arizona

John Montenegro Cruz was sentenced to death for the 2003 murder of Officer Patrick O'Hagan in Arizona. At sentencing, the jury was not told that a life sentence meant no parole eligibility, conflicting with the Supreme Court's 2016 ruling in Lynch v. Arizona. Cruz sought post-conviction relief, but the Arizona Supreme Court held that Lynch did not apply retroactively and denied relief. Cruz appealed to the U.S. Supreme Court, arguing the state's refusal violated federal due process. In a 5-4 decision on February 22, 2023, the Supreme Court ruled that Arizona's procedural bar contradicted clearly established federal law, as Lynch merely applied settled precedent. The Court reversed and remanded, entitling Cruz to a new sentencing phase where the jury would be properly instructed.

The U.S. Supreme Court reversed the Arizona Supreme Court's judgment in a 5-4 decision, holding that the state court's refusal to apply Lynch v. Arizona violated federal law, and remanded the case for a new sentencing proceeding.

Whether a state may deny post-conviction relief by refusing to retroactively apply a U.S. Supreme Court decision that merely applied a clear, pre-existing constitutional rule, thereby violating the defendant's right to due process.

The ruling reinforced the binding nature of federal constitutional precedent on state courts in capital cases. It strengthened procedural protections for death-row inmates by ensuring juries are fully informed about parole ineligibility, affecting similar cases nationwide and clarifying the retroactivity of Supreme Court decisions that apply settled law.