State of Arizona v. Efren Medina
232 Ariz. 391
| Ariz. | 2013Background
- In 1993 Efren Medina and accomplices assaulted, dragged into the street, and repeatedly ran over a 71‑year‑old victim; physical and trace evidence linked Medina to the crime.
- Medina was convicted in 1995 of first‑degree murder and sentenced to death; this Court affirmed in 1999.
- In 2003 the trial court granted post‑conviction relief as to sentencing (ineffective assistance) and vacated the death sentence, leading to resentencing proceedings.
- A 2008 penalty jury found four aggravators but hung on sentence; the court impaneled a new jury in 2009 which returned a death sentence.
- On automatic appeal, Medina raised multiple challenges including denial of a second PCR, suppression (unsigned warrant), double jeopardy and Eighth Amendment challenges to retrial after a hung penalty jury, juror voir dire and removals, Batson claims, Confrontation Clause over an autopsy report, and sentencing proportionality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of second PCR & suppression of evidence from an unsigned warrant | Medina: trial court abused discretion by denying PCR without evidentiary hearing and should have suppressed evidence from an unsigned warrant | State: PCR claim precluded (no timely appellate review) and claims waived from earlier proceedings; PCR properly denied on merits | Court: PCR denial affirmed — claim precluded by rule and, on merits, newly offered witness (Giles) lacked credibility; warrant challenge waived; no suppression error |
| Retrial after hung penalty jury — double jeopardy / Eighth Amendment | Medina: retrial after hung jury on penalty violates Double Jeopardy and constitutes cruel and unusual punishment (national consensus against retrial) | State: hung jury is ‘‘manifest necessity’’; retrial permitted by A.R.S. §13‑752(K); Arizona procedure complies with precedent and Eighth Amendment | Court: Retrial permitted; no acquittal occurred; §13‑752(K) constitutional and not cruel and unusual; death sentence not disproportionate |
| Voir dire stipulation and dismissal/removal of jurors (including Batson) | Medina: court erred by accepting counsel’s stipulation to dismiss jurors over his objection; certain jurors wrongly removed for cause; peremptory strikes were racially motivated | State: counsel can make strategic voir dire decisions and stipulate; removals were supported by demeanor and answers; prosecutor gave race‑neutral reasons for strikes | Court: Counsel’s strategic stipulation binds defendant absent sham; removals for cause justified (deference to demeanor); Batson challenges not clearly erroneous given race‑neutral explanations and presence of minority jurors on panel |
| Confrontation Clause — admission of autopsy report and expert testimony about it | Medina: autopsy report is testimonial and admission without author’s testimony violated Crawford; expert’s reliance compounded violation | State: autopsy report is nontestimonial/public record and testifying examiner gave independent opinions | Court: Autopsy report held nontestimonial under prevailing tests (Williams plurality and Thomas’s concurrence); expert testimony permissible because he formed independent conclusions; Confrontation Clause not violated |
Key Cases Cited
- State v. Medina, 193 Ariz. 504 (affirming original conviction and relevant on aggravator interpretation) (1999)
- State v. Fisher, 141 Ariz. 227 (defining requirements for newly discovered evidence in PCR) (1984)
- Sattazahn v. Pennsylvania, 537 U.S. 101 (retrial after hung jury does not violate double jeopardy) (2003)
- Yeager v. United States, 557 U.S. 110 (hung jury as manifest necessity for mistrial) (2009)
- Crawford v. Washington, 541 U.S. 36 (Confrontation Clause bars admission of testimonial out‑of‑court statements absent opportunity to cross‑examine) (2004)
- Melendez‑Diaz v. Massachusetts, 557 U.S. 305 (documents prepared for prosecution can be testimonial) (2009)
- Williams v. Illinois, 132 S. Ct. 2221 (plurality analysis on primary purpose test for testimonial evidence) (2012)
- Ring (Ring III), 204 Ariz. 534 (procedural principles on resentencing and review) (2003)