State of Arizona v. Steven John Parker
231 Ariz. 391
| Ariz. | 2013Background
- Parker was convicted of two murders of Wayne and Faye Smith and sentenced to death after a jury trial.
- Murder date: Smiths killed around Sept. 24–26, 2005; Parker’s DNA and a napkin DNA matched the crime scene.
- Parker fled after the murders, traveled to Mexico, California, Las Vegas, and was arrested Oct. 13, 2005; later reflected in trial strategy.
- Parker previously pleaded guilty to stealing from his employer; later DNA testing linked him to the Smiths’ kitchen blood and napkin.
- Three aggravating factors were found: pecuniary gain, especial cruelty, and multiple homicides.
- The State appealed through the automatic direct-review framework under Arizona law and the conviction(s) and death sentences were affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Parker’s speedy-trial right was violated. | Parker | State kept delay; Parker alleged violation | No Sixth Amendment violation; delay not prejudicial. |
| Whether voir dire restrictions on death-penalty questions were abusive. | Parker | Morgan-based probing limited | No abuse; Morgan inquiry limited but adequately addressed. |
| Whether admission of Capital One credit-card records and timesheets violated the Confrontation Clause or hearsay rules. | Parker | Records admissible as business records; cross-examination available | Business records properly admitted; no Confrontation Clause violation. |
| Whether flight instruction properly educated jurors about consciousness of guilt. | Parker | Flight evidence supports inference | Flight instruction proper under standard cases. |
| Whether the trial court should have given a third-party culpability instruction. | Parker | Instruction not required; evidence inadequate | No reversible error; no mandatory third-party instruction. |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (speedy-trial factors guide delay analysis)
- Vermont v. Brillon, 129 S. Ct. 1283 (2009) (blame for delay on government or defense; Brillon factors)
- State v. Spreitz, 190 Ariz. 129 (1997) (prejudice and delay analysis for speedy trial under Arizona law)
- Morgan v. Illinois, 504 U.S. 719 (1992) (right to voir dire to reveal jurors' death-penalty views; Morgan standard)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (confrontation in procurement of laboratory evidence; business records exception not inherently testimonial)
- Crawford v. Washington, 541 U.S. 36 (2004) (confrontation clause; testimonial statements must be cross-examined)