State of Arizona v. Edward James Rose, 231 Ariz. 500

Rose fatally shot a Phoenix police officer after forging checks; he pled guilty to two first-degree murder counts and eight other felonies, and was sentenced to death after aggravation and penalty phases.
The State charged Rose with on-duty officer murder and related felonies; on the day trial began, Rose pled guilty to all charges.
The jury found four aggravating factors and imposed a death sentence.
During sentencing, the State presented extensive victim-impact evidence (VIE); objections were raised but most were overruled or not preserved.
Rose challenged arraignment/participation in jury selection, the exclusion of non-English-speaking jurors, the voluntariness of the plea, the admissibility of VIE, and the validity of the (F)(10) aggravating factor; the Arizona Supreme Court affirmed the convictions and death sentence.
The court held that Rose’s guilty pleas were voluntary, that any absence from early jury screening did not constitute fundamental error, that non-English-speaking jurors could be excused, that VIE was permissible and not fundamental error given preservation and context, and that the (F)(10) on-duty officer aggravator is constitutional and properly applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Arraignment and jury prescreening absence	Rose objected to arraignment and early screening.	Waiver by counsel or defendant allowed absence.	No fundamental error; arraignment valid and waiver upheld.
Exclusion of non-English-speaking jurors	Violates Sixth and Fourteenth Amendments; § 21-202(B)(3) unconstitutional.	Lawful exclusion of non-English speakers.	Lawful; statute not unconstitutional; no error found.
Voluntariness of guilty plea	Plea was involuntary due to mental state and insufficient canvass.	Plea canvass satisfied Rule 17.2; competent and voluntary.	Plea voluntary, intelligent, and knowingly entered.
Victim impact evidence (VIE) at penalty	VIE admissible to show harm and impact; relevant.	VIE may be prejudicial; potential for unfair prejudice.	VIE admissible; no fundamental error; court cautioned on limits.
Constitutionality of aggravating factor (F)(10)	Factor constitutional; guides death eligibility.	Factor unfair or unconstitutional as applied.	(F)(10) constitutional; properly applied.

Henderson v. Morgan, 426 U.S. 637 (U.S. 1976) (distinguished where defendant knew required mens rea; no automatic plea validation failure)
Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (necessity of knowing waiver of rights in plea)
State v. Djerf, 191 Ariz. 583 (Ariz. 1998) (guilty plea must be voluntary and knowing; canvass requirements)
State v. Morris, 215 Ariz. 324 (Ariz. 2007) (waiver of presence; exceptions to presence rights in trial)
State v. Ovante, 231 Ariz. 180 (Ariz. 2013) (competency and competency hearings; effect on plea)
State v. Ellison, 213 Ariz. 116 (Ariz. 2006) (relevance and admissibility of victim-impact statements)
Payne v. Tennessee, 501 U.S. 808 (U.S. 1991) (victim-impact evidence permissible in sentencing)
State v. Cruz, 218 Ariz. 149 (Ariz. 2008) (elements of felony murder and required intent)
State v. Chappell, 225 Ariz. 229 (Ariz. 2010) (execution-impact evidence exclusion guidance)
State v. Roque, 213 Ariz. 193 (Ariz. 2006) (VIE admissibility and preclusion standards)
Cañez, 202 Ariz. 133 (Ariz. 2002) (pecuniary gain aggravator standards)
Lamar, 210 Ariz. 571 (Ariz. 2005) (motive for murder and pecuniary gain)
Arizona v. Arnett, 119 Ariz. 38 (Ariz. 1978) (statutory standards for capital sentencing)