Cruz v. Arizona

In Cruz v. Arizona, the U.S. Supreme Court on February 22, 2023, ruled 5-4 that Arizona courts had not applied an adequate and independent state procedural rule to bar John Montenegro Cruz's claim that his death sentence violated due process under Simmons v. South Carolina. Cruz was convicted of murdering Tucson police officer Patrick Hardesty in 2003 and sentenced to death. He argued the jury was not told he would be ineligible for parole if sentenced to life. The Arizona Supreme Court held the claim was procedurally barred because Cruz did not raise it at trial. The U.S. Supreme Court, in an opinion by Justice Sotomayor, held that Arizona's procedural rule was not firmly established or regularly applied at the relevant time, so federal review was not precluded. The case was vacated and remanded.

The U.S. Supreme Court reversed the Arizona Supreme Court and remanded the case, holding 5-4 that federal review was not procedurally barred. The Court did not decide the merits of the Simmons claim in this appeal but allowed further proceedings in lower courts.

Whether Arizona's procedural rule barring Cruz's Simmons claim was an adequate and independent state-law ground sufficient to preclude federal habeas review; whether due process required the sentencing jury to be informed of parole ineligibility when life without parole was the only alternative to death.

The decision reinforced Simmons protections in capital cases by limiting state procedural bars when state rules are not consistently applied. It affected Arizona and other states' death penalty sentencing procedures, requiring accurate jury instructions on parole ineligibility and reaffirming due process rights of capital defendants regarding sentencing juries' access to critical sentencing information.