State v. Israel Joseph Naranjo, 234 Ariz. 233

Background

In March 2007 Israel Naranjo stabbed and killed his pregnant girlfriend, Delia Rivera, and the unborn child; he confessed after arrest and was charged with two counts of first-degree murder.
A jury rejected Naranjo’s insanity defense, convicted him of both murders, found aggravators (prior serious offense, especially cruel murder; and prior serious offense plus adult killing an unborn child), and sentenced him to death on each count.
Pretrial and trial disputes included a suppression motion over the Miranda waiver and voluntariness of his confession, extensive discovery and expert-disclosure fights (several defense experts were partially or wholly precluded), challenges to jury selection (strike for cause and deleted questionnaire items), and other-act evidence from a 2003 police report.
The trial court denied suppression, struck a juror for cause based on demeanor and equivocal answers, limited the defense questionnaire but permitted oral voir dire, and sanctioned the defense under Ariz. R. Crim. P. 15.7 by precluding or limiting testimony of three defense experts for untimely disclosure or noncompliance with court orders.
On appeal Naranjo raised multiple claims (Miranda waiver, juror exclusion, questionnaire, expert preclusion, other-act evidence, expert qualification, systemic ineffective assistance / mistrial), and challenged the sufficiency of evidence for the especially-cruel aggravator and the imposition of death. The Arizona Supreme Court affirmed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Naranjo)	Held
Miranda waiver / voluntariness	Waiver was valid; interrogation video and prior law-enforcement contacts show understanding	Naranjo was psychotic and incapable of knowingly, intelligently waiving Miranda	Court: waiver valid; mental illness alone insufficient to invalidate waiver; no abuse of discretion denying suppression
Juror 36 struck for cause	Juror’s written and oral equivocation plus emotional demeanor justified cause strike	Strike violated due process and fair-trial rights	Court: deference to trial judge on demeanor; no abuse of discretion in striking juror
Deletion of questionnaire questions	Court retained oral voir dire and allowed follow-up; questionnaire not a required right	Deletion prevented meaningful voir dire on insanity, killing of pregnant women, mental-health mitigation	Court: no abuse of discretion; defense had opportunity to question orally and failed to show biased seated jury
Preclusion of Steve Brown (mental-health observer)	Preclusion appropriate given four-year lack of diligence and late disclosure prejudiced State	Brown’s firsthand observations were vital; reading notes into record insufficient	Court: preclusion within discretion given willful lack of diligence and prejudice to State
Partial preclusion of Dr. Switzky (revised IQ opinion)	Untimely new assessment prepared after damaging cross warranted limiting testimony to earlier disclosed report	New opinion critical to mitigation; continuance would cure prejudice	Court: partial preclusion permissible; trial court could find willful misconduct and lesser sanctions inadequate
Preclusion of Dr. Wu (PET scan data)	Noncompliance with court orders and failure to produce raw data prevented meaningful cross; preclusion proper	Excluding mitigation evidence violated Eighth Amendment right to present mitigation	Court: preclusion not abuse; absent raw data State could not test or rebut; defendant must follow procedures
Other-act evidence (2003 police report)	Portions probative of insanity (e.g., statements about faking mental illness) admissible	Use of profane, threatening remarks was prejudicial propensity evidence	Court: some statements admissible as relevant to sanity; other violent/profane remarks were improper but not fundamental error given overwhelming evidence of guilt
Qualification of State expert Dr. Bayless	He met §13-753(K)(2) requirements as a licensed psychologist with testing/evaluation experience	Insufficient specialized experience to qualify under statute	Court: trial court did not abuse discretion; qualification challenges go to weight, not admissibility
Systemic counsel management / mistrial	State urged no structural deprivation of counsel; trial record shows meaningful adversarial testing	Deficient contract-attorney management impaired preparation, requiring mistrial	Court: no complete deprivation or failure to test prosecution; claims mainly ineffective-assistance issues for postconviction relief; no mistrial needed
Sufficiency of aggravator (especially cruel) and death sentence	Evidence (defensive wounds, victim’s screams, eyewitness) supports cruelty and sentence	Claimed intoxication/mental issues undermined knowledge and cruelty finding	Court: reasonable evidence supports especially-cruel aggravator and jury’s decision that mitigation not sufficiently substantial; death sentences affirmed

Key Cases Cited

Uttecht v. Brown, 551 U.S. 1 (2007) (trial judge’s demeanor assessments entitled to deference)
Wainwright v. Witt, 469 U.S. 412 (1985) (juror may be excused for cause if views on capital punishment would substantially impair duties)
Witherspoon v. Illinois, 391 U.S. 510 (1968) (jurors with general conscientious scruples against death penalty may not be excluded for cause)
State v. Killean, 185 Ariz. 270 (1996) (preclusion of evidence may be proper for willful disclosure violations)
State v. Moody, 208 Ariz. 424 (2004) (discretion over jury questionnaires and voir dire procedures)
State v. Smith, 140 Ariz. 355 (1984) (factors trial court must consider before excluding witnesses for discovery violations)
State v. Hampton, 213 Ariz. 167 (2006) (preclusion of mitigation testimony can be sanction for discovery noncompliance)
Lockett v. Ohio, 438 U.S. 586 (1978) (capital sentencing requires consideration of all relevant mitigating evidence)
State v. Roque, 213 Ariz. 193 (2006) (limits on other-act evidence and propensity use)
State v. Delahanty, 226 Ariz. 502 (2011) (standard for reviewing aggravator findings and abuse-of-discretion review)