Ruth V. McGregor

The case involved challenges by the Arizona Minority Coalition for Fair Redistricting and others to the congressional and state legislative district maps created by the Arizona Independent Redistricting Commission after the 2000 census under the process established by Proposition 106. The Arizona Supreme Court considered the constitutional guidance provided to the Commission and the limits of judicial oversight of its decisions. The court held that judicial review is confined to determining whether the Commission followed the required procedural steps, such as starting with a grid map and adjusting it to accommodate the listed goals in order, without evaluating the Commission's discretionary balancing of those goals or its methodologies. The reasoning centered on the constitutional assignment of redistricting authority to the independent Commission and the need to respect its role while ensuring basic procedural compliance.

electionscivil rights

In this case, Brian Jeffrey Dann was convicted in 2001 of three counts of first-degree murder and one count of first-degree burglary after killing multiple victims. Following the U.S. Supreme Court's decision in Ring v. Arizona, which required jury findings on aggravating factors for death sentences, Dann was resentenced in 2007 by a new jury that found the multiple-murders aggravator and determined that the mitigating circumstances were not substantial enough to warrant leniency. On automatic appeal, the Arizona Supreme Court affirmed the death sentences, holding that the jury's findings were proper and that any prior judge-only sentencing errors were harmless. The court rejected various constitutional challenges to the sentencing process and procedures.

criminal law

The case involved two consolidated wrongful death actions against the State of Arizona and its Department of Corrections, arising from alleged negligence in providing medical care to prisoners who died in custody. Before filing suit, the plaintiffs submitted notices of claim that specified settlement amounts and included supporting facts such as the decedents' ages, life expectancies, and annual loss calculations. The trial courts dismissed the complaints for failure to comply with A.R.S. § 12-821.01.A, and the court of appeals affirmed, but the Arizona Supreme Court reversed and remanded. The court held that the statute requires only that a notice set forth a specific amount and the facts the claimant regards as supporting that amount, without mandating any particular level of detail or additional verification. Both notices satisfied this standard, and the court noted that public entities may request more information if needed while claimants face professional and evidentiary consequences for misrepresentations.

proceduretorts & liability

In State v. Thomas, the Arizona Supreme Court addressed whether a conviction for aggravated assault could qualify as a historical prior felony conviction to enhance sentences for later drug-related convictions under A.R.S. § 13-604.W.2(a), even though the assault acts occurred after the drug offenses. The trial court had applied the enhancement because the assault conviction preceded the drug convictions, but a divided court of appeals vacated the enhanced sentences, requiring that the underlying offense also predate the sentencing offenses. The Supreme Court vacated the appellate decision and affirmed the trial court's sentences, reasoning that the statute's plain language imposes a timing requirement only on the dates of conviction for the enumerated felonies, not on when the offenses were committed.

criminal law

The case involved Phillip Alan Bocharski, who was convicted by a jury of first-degree felony murder and first-degree burglary. After an initial death sentence was reversed on appeal due to insufficient mitigation investigation funding, a new jury on resentencing found two aggravating factors—the murder was especially heinous or depraved and the victim was over seventy years old—and imposed the death penalty. On automatic appeal, the Arizona Supreme Court reduced the sentence to natural life imprisonment, reasoning that the aggravating evidence was limited while the mitigation evidence was substantial, and resolving any doubt in favor of a life sentence.

criminal law

This case arose when Michael Cullen and Jana Coronado sued Auto-Owners Insurance for breach of contract and bad faith after the insurer denied Cullen's claim for underinsured motorist benefits under a policy covering a vehicle used by Coronado's family. The trial court dismissed the complaint under Arizona Rule of Civil Procedure 12(b)(6) for failure to state a claim, and the court of appeals affirmed while discussing the pleading standard from Bell Atlantic Corp. v. Twombly. The Arizona Supreme Court granted review to address confusion over whether Twombly had replaced Arizona's notice pleading rule. The court held that Arizona Rule of Civil Procedure 8(a)(2) continues to require only a short and plain statement showing entitlement to relief, as previously interpreted by the court, and therefore vacated the portion of the appellate opinion citing Twombly while affirming the remainder of the judgment, including the dismissal.

procedurebusiness & regulatory