State of Arizona v. William Craig Miller, 485 P.3d 554

William Craig Miller was convicted in 2011 of five counts of first‑degree murder and sentenced to death; the jury found four aggravators.
At the penalty phase the court, without objection, read the pre‑2016 RAJI (Revised Arizona Jury Instruction) defining the (G)(1) statutory mitigator using the phrase that the defendant’s impairment “prevented” appreciation or conforming of conduct.
Miller presented substantial mitigation evidence (bipolar disorder, childhood issues, family history, impulse control problems); the jury rejected it and imposed death; this Court affirmed on direct appeal.
In 2016 the State Bar committee revised the RAJI to replace “prevented” with language like “substantially reduced,” and in later decisions the State conceded the pre‑2016 RAJI was erroneous.
A PCR court granted relief, finding trial and appellate counsel ineffective for failing to challenge the RAJI and that Miller was prejudiced; the Arizona Supreme Court granted review and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was constitutionally deficient for not objecting to the RAJI’s “prevented” language	Miller: counsel’s failure to challenge an incorrect instruction shows ignorance of the law and falls below prevailing professional norms	State: widespread use of the RAJI and court adoption made counsel’s failure to object reasonable	Court: No deficiency — given the RAJI’s provenance, judicial use, ambiguity of “prevented,” and lack of evidence that defense community questioned it, counsel’s performance was reasonable
Whether any deficiency prejudiced Miller’s penalty‑phase outcome	Miller: the erroneous RAJI curtailed jurors’ consideration of his mental‑health mitigation and likely changed the sentence	State: other instructions allowed jurors to consider the same mitigation; jury rejected mitigation after weighing aggravators and mitigation	Court: No prejudice — reweighing shows jurors could and did consider the mental‑health evidence under other mitigators and would not reasonably have reached a different result

Strickland v. Washington, 466 U.S. 668 (establishes two‑part ineffective assistance test)
Hinton v. Alabama, 571 U.S. 263 (reasonableness judged by prevailing professional norms)
Padilla v. Kentucky, 559 U.S. 356 (professional norms as guide but not dispositive)
Bobby v. Van Hook, 558 U.S. 4 (consult prevailing norms at time of representation)
Wiggins v. Smith, 539 U.S. 510 (prejudice requires reweighing aggravation and mitigation)
Berghuis v. Thompkins, 560 U.S. 370 (Strickland prejudice and totality of evidence instruction)
State v. Johnson, 247 Ariz. 166 (State conceded pre‑2016 RAJI was erroneous)
State v. Miller, 234 Ariz. 31 (affirming convictions and sentences on direct appeal)
State v. Trostle, 191 Ariz. 4 (judicial adoption of instructions lends credibility)
State v. Pandeli, 242 Ariz. 175 (standards of review for mixed questions of law and fact)