The US Supreme Court Wednesday granted a request by death row inmate John Cruz for post conviction relief from his 2005 death sentence. In an opinion by Justice Sotomayor, the court ruled that the Arizona Supreme Court incorrectly held that the 2016 case Lynch v. Arizona was “not a significant change in law” meriting a second post conviction relief application.
In Lynch, the US Supreme Court overruled the Arizona Supreme Court’s determination that the case Simmons v. South Carolina “did not apply” in Arizona. Under Simmons, defendants convicted of murder who are not eligible for parole must be allowed to share this information with the jury, so the jury may consider a life sentence rather than the death penalty.
Cruz filed a second post conviction relief petition after the Lynch ruling. A second request is generally not allowed, but according to the Arizona Rule of Criminal Procedure 32.1(g), second post conviction relief requests may be made following significant changes in the law. Arizona courts denied that the Lynch ruling was a significant change in the law, calling it only a change in the application of the law. In Wednesday’s ruling, the US Supreme Court determined that Arizona incorrectly disallowed Cruz’s request because the federal Simmons decision overruled binding state court precedent, effectively altering the ability for capital defendants to inform the jury of their ineligibility for parole.
The court vacated Cruz’s case and remanded it for further proceedings.