State of Arizona v. valencia/healer
241 Ariz. 206
| Ariz. | 2016Background
- In 1994–1995, juveniles Joey Lee Healer (16) and Gregory Nidez Valencia Jr. (17) committed separate first‑degree murders and were sentenced to natural life imprisonment (no possibility of release) under Arizona law then in effect.
- At sentencing the trial courts considered mitigating factors including the defendants’ ages; Arizona statutes required consideration of age but parole had been abolished for offenses after Jan 1, 1994, and natural life excluded earned‑release credits.
- After the U.S. Supreme Court decided Miller v. Alabama (2012) and Montgomery v. Louisiana (2016), Healer and Valencia filed Rule 32.1(g) petitions arguing Miller (as made retroactive by Montgomery) invalidated their natural life sentences for juvenile homicide.
- Trial courts summarily denied relief, finding sentencing courts had considered age and that 2014 Arizona statutory amendments addressed any scheme defects; the court of appeals granted relief and ordered resentencing.
- The Arizona Supreme Court granted review to decide whether Miller/Montgomery constitute a “significant change in the law” under Rule 32.1(g) and whether petitioners are entitled to evidentiary hearings and relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller (as clarified by Montgomery) is a "significant change in the law" under Ariz. R. Crim. P. 32.1(g) | Miller/Montgomery announce a new substantive rule barring life‑without‑parole for most juvenile offenders and thus is a significant change entitling relief | Miller only prohibited mandatory LWOP and was satisfied here because sentencing courts considered age | Yes — Miller, as clarified by Montgomery, is a clear break from past law and a significant change for Rule 32.1(g) purposes. |
| Whether Miller is merely procedural or substantive and whether it is retroactive | Miller (per Montgomery) is substantive and applies retroactively to cases on collateral review | Miller announced only a procedural rule requiring individualized sentencing; not retroactive | Montgomery holds Miller is substantive and retroactive; state courts must give it retroactive effect. |
| Whether a sentencing court’s prior consideration of age satisfies Miller/Montgomery | Prior consideration of age is insufficient if the record does not show the juvenile’s crime lacked “irreparable corruption” | Because the sentencing court considered age and other mitigators, the sentence complied with Miller | Prior consideration alone may not suffice; petitioners are entitled to show their crimes reflected transient immaturity rather than irreparable corruption. |
| Appropriate remedy: resentencing vs parole eligibility | Petitioners seek resentencing or relief under Miller/Montgomery | State argues prior procedures and later statutes address concerns; legislature can provide parole eligibility instead of resentencing | Court orders evidentiary hearings; alternatively legislature may permit parole consideration, but judiciary cannot impose that statutory change. |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (holding mandatory life‑without‑parole for juveniles violates the Eighth Amendment and youth must be considered)
- Montgomery v. Louisiana, 136 S. Ct. 718 (clarifying Miller announces a substantive rule with retroactive effect; relief available to juveniles serving LWOP)
- Roper v. Simmons, 543 U.S. 551 (Eighth Amendment prohibits death penalty for offenders under 18; youth differences relevant to sentencing)
- State v. Vera, 235 Ariz. 571 (App. 2014) (discusses Arizona parole/earned‑release scheme and applicability to juvenile sentences)