State v. Scroggins, 1 CA-CR 16-0670-PRPC

Scroggins was charged with first-degree murder, aggravated assault, and kidnapping; he claimed self-defense.
Defense counsel orally moved for a continuance pretrial to investigate a Social Security letter indicating past mental-health-based disability (schizophrenia/paranoia), but the letter lacked details and records were reportedly destroyed; the court denied the continuance.
Scroggins rejected a plea offer the same day the continuance was denied, then later pled guilty to second-degree murder under a stipulated 22–25 year sentencing range; other counts were dismissed.
After plea acceptance and a change-of-plea colloquy finding the plea knowing and voluntary, Scroggins moved to withdraw his plea and later sought post-conviction relief arguing the court should have granted the continuance to investigate mental-health issues; the superior court denied relief.
The court considered mental-health information at sentencing, denied additional time to investigate mitigation, and sentenced Scroggins to 23.5 years.
On appeal, the court reviewed whether denial of the continuance and denial of a competency evaluation required relief and whether any error was waived by the guilty plea.

Issue	Scroggins' Argument	State's Argument	Held
Whether denial of pretrial continuance to investigate mental-health evidence was reversible	Court should have granted continuance to investigate SSDI letter and possible Rule 11 issues	Denial was within trial court discretion; defense had limited grounds and no Rule 11 request	Denial not reversible; plea waived non-jurisdictional challenges and no abuse of discretion shown
Whether Scroggins waived challenge to pre-plea errors by pleading guilty	Plea was pressured and uninformed due to lack of mental-health investigation	Guilty plea was knowing, voluntary, and waives prior non-jurisdictional claims	Waived: plea forecloses independent pre-plea constitutional claims per Tollett v. Henderson
Whether denial of continuance caused prejudice affecting outcome	Lack of investigation prevented presentation of meaningful mitigation or a different outcome	No evidence denial altered outcome; sentencing considered mental-health mitigation	No prejudice shown; sentencing within agreed range and record lacks proof of different result
Whether a competency evaluation should be ordered	Scroggins alleged mental illness and requested competency evaluation	No contemporaneous evidence of incompetence; only an SSDI letter without supporting medical records	Denied: mere history of mental illness is insufficient for Rule 11 competency finding without evidence of incapacity

Tollett v. Henderson, 411 U.S. 258 (1973) (guilty plea waives independent pre-plea constitutional claims)
State v. Moreno, 134 Ariz. 199 (App. 1982) (guilty plea waives non-jurisdictional defects)
State v. Amaya-Ruiz, 166 Ariz. 152 (1990) (continuance decision reviewed for abuse of discretion and prejudice)
State v. Gutierrez, 229 Ariz. 573 (2012) (appellate review standard for post-conviction rulings)
State v. Hamilton, 142 Ariz. 91 (1984) (statements at plea colloquy are normally binding on defendant)