Cruz v. Arizona

“An unforeseeable and unsupported state-court decision on a question of state procedure does not constitute an adequate ground to preclude this Court’s review of a federal question.” Bouie v. City of Columbia, 378 U. S. 347, 354 (1964).

On trial for capital murder, Petitioner argued that pursuant to Simmons v. South Carolina he should inform the jury that a life sentence in Arizona is without parole but the court deemed Simmons was inapplicable. Petitioner was convicted and this Court decided in Lynch v. Arizona that Simmons did apply in Arizona. Petitioner then filed a motion for post conviction relief under Arizona Rule of Criminal Procedure 32.1(g), arguing that the decision in Lynch was a significant change in the law, which satisfied the requirement pursuant to Rule 32.1(g) to overturn his sentence. Arizona denied relief, finding that Lynch was not a substantial change in the law but rather was a change in application of the law. On appeal, the Supreme Court determined whether Arizona’s holding was an adequate and independent state law ground for judgment. The Court held that Arizona’s holding was inadequate as it rested on a unforeseeable interpretation of Rule 32.1(g),  reasoning that Arizona’s application of Rule 32.1(g) to Lynch was inadequate because since Lynch had overruled state precedent, it constitutes as a substantial change in law. The Court also reasoned that Arizona’s interpretation that  Lynch was a change in application of the law was contrary to the state’s prior case law as there was no distinction previously made between a substantial change in the law generally and a substantial change in the application of the law as Arizona’s new interpretation suggests. Therefore, Arizona’s interpretation was inadequate. VACATED and REMANDED.