State v. Gonzalez
1 CA-CR 21-0087
| Ariz. Ct. App. | Feb 24, 2022Background
- At 17, Jesus Andres Gonzalez participated with six accomplices in three armed home invasions during one evening; he was armed with a handgun.
- At the third residence Gonzalez threatened occupants and fatally shot a man; at other homes he pistol-whipped and assaulted victims and stole property.
- A jury convicted Gonzalez of first-degree murder and kidnapping, three counts of first-degree burglary, and seven counts of aggravated assault.
- The superior court sentenced him to life for murder (eligible for release after 25 years) and imposed concurrent and consecutive terms on other counts for a minimum cumulative incarceration of 60.5 years.
- Mid-trial Gonzalez told counsel he was hearing voices and had schizophrenia; defense counsel planned an evaluation, but the court reviewed medical records in camera, found ongoing treatment and no clear signs of incompetence, and did not order a formal Rule 11 competency exam.
- On appeal Gonzalez argued (1) the trial court erred by failing to sua sponte order a mid-trial competency evaluation and (2) his 60.5-year minimum sentence is cruel and unusual because he was a juvenile.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Gonzalez) | Held |
|---|---|---|---|
| Whether the trial court erred by failing to sua sponte order a mid-trial competency (Rule 11) evaluation | No error; court observed defendant, reviewed records, and properly exercised discretion; no reasonable grounds for Rule 11 | Structural error: defendant was hearing voices and had schizophrenia, so court should have ordered a competency exam sua sponte | No error. Court reviewed medical records, observed defendant, and reasonably concluded no Rule 11 exam required; no abuse of discretion |
| Whether Gonzalez’s aggregate ~60.5-year minimum sentence violates the Eighth Amendment / Arizona Constitution because he was a juvenile | Soto-Fong controls; sentence constitutional given severity | Sentence is a de facto life term for a juvenile and thus cruel and unusual | Rejected. Must follow State v. Soto-Fong; given multiple violent offenses across locations, sentence not disproportionate |
Key Cases Cited
- State v. Amaya-Ruiz, 166 Ariz. 152 (1990) (trial court has continuing duty to inquire into competency and must order Rule 11 exam if reasonable grounds exist)
- State v. Salazar, 128 Ariz. 461 (1981) (reasonable grounds exist when evidence indicates defendant cannot understand proceedings or assist in defense)
- Indiana v. Edwards, 554 U.S. 164 (2008) (presumption that criminal defendant is competent unless evidence to the contrary)
- State v. Glassel, 211 Ariz. 33 (2005) (court may rely on in-court observations to assess competency)
- State v. Soto-Fong, 250 Ariz. 1 (2020) (rejecting Eighth Amendment challenge to lengthy sentence for juvenile defendant)