State of Arizona v. Craig Victor Coleman
241 Ariz. 190
| Ariz. Ct. App. | 2016Background
- In Sept. 2012 Coleman entered a backyard, grabbed a 3-year-old (H.T.), struck the child’s mother (C.B.), and fled; jury convicted Coleman of unlawful imprisonment of a minor (lesser-included of kidnapping), aggravated assault of a minor, assault, and burglary.
- The jury specifically found the unlawful imprisonment was not proven to be sexually motivated beyond a reasonable doubt.
- Trial court sentenced Coleman to concurrent terms (longest 2.5 years) and ordered ten years of registration under A.R.S. § 13-3821(A)(1) (sex-offender registry).
- Coleman appealed, arguing the registration order violated his equal protection and substantive due process rights because the jury found no sexual motivation and unlawful imprisonment has no sexual element.
- The court reviewed constitutional claims de novo (equal protection) and for fundamental, prejudicial error (substantive due process, raised for first time on appeal).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ordering registration under A.R.S. § 13-3821(A)(1) for unlawful imprisonment of a minor (without a jury finding of sexual motivation) violates equal protection | Coleman: registration and "sex offender" labeling when no sexual element is found is not rationally related to the legislature’s purpose of regulating sex offenders | State: statute rationally related to protecting children and aiding law enforcement; Congress and legislature included non-parent unlawful imprisonment to address child abduction/recidivism risks | Court: statute survives rational-basis review; no equal protection violation |
| Whether the registration requirement violates substantive due process (fundamental, prejudicial error review) | Coleman: labeling and registration without sexual-motivation finding is arbitrary and shocks the conscience | State: registration is substantively rational to protect children and assist investigations; not arbitrary | Court: no substantive-due-process violation; registration does not shock the conscience |
Key Cases Cited
- City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (1985) (equal-protection rational-basis principle)
- F.C.C. v. Beach Commc’ns, Inc., 508 U.S. 307 (1993) (rational-basis review is deferential)
- Conn. Dep’t of Pub. Safety v. Doe, 538 U.S. 1 (2003) (sex-offender registration implicates substantive due process inquiry)
- State v. Lowery, 230 Ariz. 536 (App. 2012) (Arizona equal-protection analysis and §13-3821 rational-basis context)
- State v. Noble, 171 Ariz. 171 (1992) (registration statute rationally related to aiding law enforcement)
- State v. Panos, 239 Ariz. 116 (App. 2016) (rational-basis standard for classification challenges)
- State v. Smith, 780 N.W.2d 90 (Wis. 2010) (upholding registration for false imprisonment of minor as rationally related to protecting children)
