Robert J. Corcoran

In State v. Gibson, the defendant was convicted of a 1974 first-degree murder based on fingerprint evidence and testimony from his ex-wife, after the trial court precluded him from introducing evidence suggesting that two other individuals (D.B. and J.W.) might have committed the crime. The trial court had excluded this third-party culpability evidence on grounds that it lacked an inherent connection to the murder and could confuse the jury, and the court of appeals affirmed the conviction. The Arizona Supreme Court reversed, holding that admissibility of such evidence must be determined under the standard rules of relevance and prejudice (Arizona Rules of Evidence 401, 402, and 403) rather than any heightened or special test like a 'clear link' requirement. The court remanded the case for a new trial with instructions to apply the proper evidentiary balancing test to the proffered evidence about the alternative suspects.

criminal lawprocedure

In State v. Blackmore, the defendant was convicted of possession of dangerous drugs after Phoenix police detained him while investigating a nearby burglary, handcuffed him for safety, obtained his consent to retrieve identification from his car, and discovered methamphetamine in plain view during that process. The trial court denied the defendant's motion to suppress the evidence and statements, ruling the initial stop and detention were appropriate and the consent voluntary. The court of appeals reversed in a divided opinion, holding that the detention amounted to an unlawful de facto arrest without probable cause. The Arizona Supreme Court vacated the court of appeals' opinion, concluding that the seizure was a valid investigatory stop supported by specific facts and that the consent was not tainted.

criminal lawprocedurecivil rights

The case involves David O'Neal Hyde's appeal from convictions on two counts of first-degree premeditated murder and one count of first-degree burglary, stemming from the 1991 killings of a father and daughter at a Phoenix market, along with consecutive death sentences for the murders. The Arizona Supreme Court conducted an automatic review and affirmed the convictions and sentences in full. The court examined numerous claims, including issues with trial counsel's preparation and representation, the voluntariness of the defendant's statements, search procedures, and jury instructions on sentencing, concluding that the trial court committed no reversible error on any point.

criminal lawprocedure

In State v. Jones, Danny Lee Jones was convicted in Mohave County Superior Court of two counts of premeditated first-degree murder and one count of attempted premeditated first-degree murder after attacking Robert Weaver, his wife Jackie, and their seven-year-old daughter Tisha in their home, resulting in the deaths of Robert and Tisha and serious injury to Katherine Gumina. The trial court imposed two consecutive death sentences for the murders and a consecutive life sentence for the attempted murder. On automatic appeal, the Arizona Supreme Court independently reviewed the entire record, identified multiple aggravating circumstances for each murder—including pecuniary gain, cruelty or depravity, multiple homicides, and the young age of one victim—while giving limited weight to mitigating factors such as substance abuse and head injuries, and concluded that the mitigators were insufficient to call for leniency. The court found no fundamental error and affirmed the convictions and sentences.

criminal law

This case involved two British Virgin Islands corporations, Gemstar and Canstar, along with several of their shareholders, who sued the accounting firm Ernst & Young and an individual accountant for breach of contract, professional negligence, breach of fiduciary duty, and related claims arising from advice and services connected to the purchase, tax treatment, and resale of Arizona real properties. The trial court entered judgment for the plaintiffs after a jury verdict, but the court of appeals reversed on multiple grounds related to the plaintiffs' capacity to sue. The Arizona Supreme Court vacated the court of appeals' decision, holding that Gemstar and Canstar had capacity to sue because the action was properly authorized at filing and within the statute of limitations, and it affirmed the trial court's judgment in favor of the corporations without addressing the individual shareholders' capacity due to duplicative damages.

proceduretorts & liabilitybusiness & regulatory

This case involves the direct appeal of a death sentence imposed on Michael Steven Gallegos after his convictions for first-degree murder and sexual conduct with a minor under age 15. Following a prior remand for resentencing, the trial court again found two aggravating circumstances under Arizona's death penalty statute—the victim's age and the especially heinous, cruel, and depraved nature of the murder—along with several statutory and non-statutory mitigating factors such as the defendant's age and immaturity, remorse, and history of substance abuse. The trial court determined that the mitigation was not sufficiently substantial to warrant leniency and resentenced Gallegos to death. On appeal, the Arizona Supreme Court independently reviewed the aggravating and mitigating circumstances, affirmed the trial court's findings on those factors, and concluded that the mitigation did not call for a lesser sentence, thereby upholding the death penalty.

criminal law