State of Arizona v. Johnathan Ian Burns
237 Ariz. 1
| Ariz. | 2015Background
- Burns was convicted of sexual assault, kidnapping, first-degree murder, and weapon misconduct in Arizona, resulting in a death sentence during the penalty phase.
- Jackie H. disappeared after a date with Burns; her body was later found with multiple injuries and DNA evidence linking Burns to the scene.
- Evidence included burns’ blood in Burns’ truck and jeans, semen on Jackie’s underwear matched Burns, and Burns’ DNA in sperm found on Jackie’s body; a firearm connected to the homicide was recovered.
- Prior to trial, the State sought to join multiple charges; a defense motion to sever was denied, but the court later found severance was an abuse of discretion regarding the weapons conviction.
- During the penalty phase, Burns challenged various evidentiary and procedural rulings, culminating in a death verdict based on two aggravators: prior serious- offense conviction (F)(2) and especially cruel murder (F)(6).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Continuances and prejudice | Burns asserts prejudice from delayed guilt/penalty phases hampering mitigation. | Burns claims time constraints prevented presenting mitigation evidence. | No abuse; prejudice not shown; continuances adequate. |
| Voir dire on death penalty and aggravating factors | Defense sought to ask jurors about automatic death-penalty votes based on aggravators. | Morgan not entitle to morphed questions; court properly limited lines of inquiry. | Court did not abuse discretion; Morgan compliant; jurors could be asked about automatic death penalty, not based on specific facts. |
| Joinder and severance of charges | Joinder of sexual assault, kidnapping, murder, and weapons was proper; severance not required. | Misconduct-involving-weapons charge should be severed to avoid prejudice from prior felonies. | Abuse of discretion to join the weapons charge; harmless error given overwhelming guilt, but severance advisable in future. |
| GHB evidence and jury instructions | GHB in Jackie’s liver tissue supported subduing rape claim; admissible as relevant. | Origin of GHB unclear; potential prejudice. | Evidence admitted; its probative value outweighed prejudice; jury instruction on lack of consent supported by evidence; no error. |
| Mandi’s testimony and Rule 404(b) | Mandi’s statements about Burns’ threats and fear were probative to rebut fabrication. | Certain acts were improper other-acts evidence under Rule 404(b). | Testimony properly admitted to rebut credibility; not prejudicial; 404(b) does not bar this testimony in penalty phase. |
Key Cases Cited
- State v. Barreras, 181 Ariz. 516, 892 P.2d 852 (1995) (continuances require showing prejudice and indispensability)
- Morgan v. Illinois, 504 U.S. 719 (1992) (capital juror-questioning on death penalty autonomy)
- State v. Prion, 203 Ariz. 157, 52 P.3d 189 (2002) (joinder and admissibility of co-acting evidence; overlapping acts)
- State v. Hardy, 230 Ariz. 281, 283 P.3d 12 (2012) (felony-murder predicate unanimity; substantial evidence standard)
- State v. Henderson, 210 Ariz. 561, 115 P.3d 601 (2005) (harmless error and appellate review standards in improper severance claims)