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State of Arizona v. Craig Victor Coleman
241 Ariz. 190
| Ariz. Ct. App. | 2016
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Background

  • 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)
Read the full case

Case Details

Case Name: State of Arizona v. Craig Victor Coleman
Court Name: Court of Appeals of Arizona
Date Published: Nov 22, 2016
Citation: 241 Ariz. 190
Docket Number: 2 CA-CR 2015-0419
Court Abbreviation: Ariz. Ct. App.