Syllabus
Note: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
CRUZ v. ARIZONA
CERTIORARI TO THE SUPREME COURT OF ARIZONA
No. 21–846. Argued November 1, 2022—Decided February 22, 2023
Petitioner John Montenegro Cruz was found guilty of capital murder by an Arizona jury and sentenced to death. Both at trial and on direct appeal, Cruz argued that under Simmons v. South Carolina, 512 U. S. 154, he should have been allowed to inform the jury that a life sentence in Arizona would be without parole. The trial court and Arizona Supreme Court held that Arizona’s capital sentencing scheme did not trigger application of Simmons. After Cruz’s conviction became final, this Court held in Lynch v. Arizona, 578 U. S. 613 (per curiam), that it was fundamental error to conclude that Simmons “did not apply” in Arizona. Id., at 615. Cruz then sought to raise the Simmons issue again in a state postconviction petition under Arizona Rule of Criminal Procedure 32.1(g), which permits a defendant to bring a successive petition if “there has been a significant change in the law that, if applicable to the defendant’s case, would probably overturn the defendant’s judgment or sentence.” The Arizona Supreme Court denied relief after concluding that Lynch was not “a significant change in the law.”
Held: The Arizona Supreme Court’s holding that Lynch was not a significant change in the law is an exceptional case where a state-court judgment rests on such a novel and unforeseeable interpretation of a state-court procedural rule that the decision is not adequate to foreclose review of the federal claim. Pp. 7–14.
