State of Arizona v. Kevin Artice Miles, 414 P.3d 680

In 1992 Kevin Miles and juveniles carjacked Patricia Baeuerlen; an accomplice shot and killed her. Miles was convicted of first-degree felony murder, kidnapping, and armed robbery and sentenced to death; this Court affirmed on direct appeal.
Miles pursued federal habeas and then a second postconviction relief (PCR) petition under Ariz. R. Crim. P. 32.1(h) (2014), alleging newly discovered mitigation: cocaine withdrawal syndrome and alcohol-related neurodevelopmental disorder (ARND) from prenatal alcohol exposure.
The PCR court found Miles remained a major participant but that reasonable doubt existed whether he acted with the Tison culpable mental state (“reckless indifference to human life”) because of his diminished capacity; it commuted his death sentence to life with possibility of release after 25 years.
The State appealed, raising two statewide issues: (1) whether diminished-capacity and voluntary-intoxication evidence is admissible in the Enmund/Tison death-eligibility inquiry, and (2) whether newly proffered mitigation can ever satisfy Rule 32.1(h)’s clear-and-convincing standard to show a sentencer would not have imposed death.
The Supreme Court affirmed the PCR court’s Tison-based relief, holding that diminished-capacity and voluntary-intoxication evidence is admissible in the Tison inquiry if otherwise admissible under the rules of evidence; it did not decide the narrower Rule 32.1(h) interpretation question because Tison relief was dispositive.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Miles)	Held
Admissibility of diminished-capacity and voluntary-intoxication evidence in the Enmund/Tison death-eligibility inquiry	Such evidence is precluded by Arizona law (Mott) and statutes like A.R.S. §13-503; permitting it undermines legislative intent and leads to inconsistent results	Evidence of diminished capacity and intoxication is relevant to the subjective Tison mental-state inquiry and is admissible under evidentiary rules	Admissible: courts may consider diminished-capacity and voluntary-intoxication evidence in the Tison inquiry if it meets the ordinary evidentiary rules (relevance, reliability, Rule 702, etc.)
Whether newly discovered mitigation can constitute clear-and-convincing evidence under Rule 32.1(h) that a sentencer would not have imposed death	Rule 32.1(h) should be read narrowly (like federal actual-innocence standard) so PCR relief is limited	Rule 32.1(h) allows relief where clear-and-convincing evidence shows the court would not have imposed death; broader reading permits mitigation-based claims	Not resolved on merits here: Court avoided deciding the broader Rule 32.1(h) interpretation because it affirmed on the Tison eligibility ground; concurrence raised concerns about the 2000 wording and endorsed a more objective, restyled 2018 version

Enmund v. Florida, 458 U.S. 782 (discussing death-eligibility limits for felony-murder accomplices)
Tison v. Arizona, 481 U.S. 137 (establishing major-participant plus reckless-indifference standard for death eligibility)
Sawyer v. Whitley, 505 U.S. 333 (federal "actual innocence" exception standard for successive habeas death-penalty claims)
State v. Mott, 187 Ariz. 536 (refusing diminished-capacity to negate mens rea at guilt phase)
Clark v. Arizona, 548 U.S. 735 (respecting state limits on mental-health evidence at guilt phase)
State v. Ring, 204 Ariz. 534 (distinguishing Enmund/Tison proportionality inquiry from statutory elements)
State v. Schackart, 175 Ariz. 494 (relevance of mental-state expert testimony in aggravation/penalty context)
State v. Lynch, 225 Ariz. 27 (Tison subjective-appreciation standard)