State of Arizona v. Rodney Eugene Hardy
230 Ariz. 281
| Ariz. | 2012Background
- Hardy was convicted by jury of first degree burglary, kidnapping, and two counts of first degree murder, and sentenced to death on both murders.
- The crimes occurred during late August 2005 in Meleigha’s apartment, involving Hardy’s attempts to locate Tiffany and shooting Tiffany and Don.
- Hardy admitted to shooting the victims but claimed heat-of-passion manslaughter; the State pursued premeditated and felony-murder theories.
- The State relied on two aggravators: prior serious offense and multiple homicides; Hardy presented mitigating evidence in sentencing.
- During guilt, issues included Batson challenges, sufficiency of the evidence, admissibility of other-acts, and evidentiary rulings; during penalty, Simmons instruction and testimony issues were raised.
- The Supreme Court affirmed Hardy’s convictions and sentences after reviewing the challenged rulings and the death-penalty framework.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenges to juror strikes | Hardy asserts discriminatory strikes against minority jurors. | State contends no pattern of discrimination; race-neutral reasons were given. | No clear error; race-neutral explanations supported. |
| Sufficiency of the evidence for kidnapping, burglary, and felony murder | State proved each predicate offense and that deaths occurred in furtherance of those felonies. | Hardy contends killings not in furtherance of kidnapping or burglary. | Substantial evidence supports kidnapping, burglary, and felony-murder convictions. |
| Admission of other-act evidence under Rule 404(b) | Evidence of pre-crime acts shows motive/intent. | Potential prejudice or improper propensity use. | Trial court did not abuse discretion; evidence admissible for intent/plan with limiting instructions. |
| Penalty-phase Simmons instruction | Ineligibility for parole should be conveyed where applicable. | Simmons instruction not required where parole is available under law. | No Simmons instruction required; law properly stated; no due-process error. |
| Prosecutorial conduct on cross-examination regarding sentencing expert | Cross-exam questioning implied improper testimony about another case. | Any issue was cured by objection and trial court instructions. | No reversible error; implied prejudice cured by court instructions. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibits racial discrimination in peremptory strikes)
- Snyder v. Louisiana, 552 U.S. 472 (U.S. 2008) (credibility assessment of race-neutral reasons for strikes)
- Gallardo v. State, 225 Ariz. 560 (Ariz. 2010) (three-step Batson framework in Arizona)
- State v. Smith, 160 Ariz. 507 (Ariz. 1989) (advocates alternate verdict forms for dual theories of murder)
- State v. Schad, 163 Ariz. 411 (Ariz. 1989) (unanimity on form of first degree murder not required)