Opinion of the Court
reach the further issue whether the decision below is independent of federal law.[1]
III
The State and the dissent offer various reformulations of the argument that Lynch was not a “significant change in the law” for Rule 32.1(g) purposes, but each fails to grapple with the basic point that Lynch reversed previously binding Arizona Supreme Court precedent.
Both the State and the dissent argue that the Arizona Supreme Court was justified in treating Lynch differently than other transformative decisions of this Court, such as Ring v. Arizona, 536 U. S. 584 (2002), and Padilla v. Kentucky, 559 U. S. 356 (2010), because Lynch was a summary reversal and so did not “impos[e] a new or changed interpretation of state or federal law.” Brief for Respondent 12. As the dissent puts the argument: Lynch “did not change the law in Arizona.” Post, at 5 (opinion of Barrett, J.).
These arguments miss the point. While Lynch did not change this Court’s interpretation of Simmons, it did change the operative (and mistaken) interpretation of Simmons by Arizona courts. Lynch thus changed the law in Arizona in the way that matters for purposes of Rule 32.1(g): It overruled previously binding Arizona Supreme Court precedent preventing capital defendants from informing the jury of their parole ineligibility.[2]
- ↑ The Court also does not need to reach Cruz’s additional arguments that the decision below reflects an attitude of hostility toward Simmons v. South Carolina, 512 U. S. 154 (1994) (plurality opinion), and Lynch v. Arizona, 578 U. S. 613 (2016) (per curiam), and impermissibly discriminates against federal law by nullifying Cruz’s rights under Simmons.
- ↑ At oral argument, the State also argued that Lynch, at the very least, was not a “significant” change in the law. Tr. of Oral Arg. 34–36. By any measure, though, Lynch was a “transformative event,” State v. Shrum, 220 Ariz. 115, 118, 203 P. 3d 1175, 1178 (2009), in Arizona. In fact, the State conceded Lynch was a “clear break” from the past in Arizona courts. Tr. of Oral Arg. 36.
