State v. Travis Wade Amaral
239 Ariz. 217
| Ariz. | 2016Background
- In 1993 Travis Wade Amaral (then 16) pled guilty to two counts of first‑degree murder and attempted armed robbery and received consecutive life terms with parole eligibility after 57.5 years.
- At sentencing the court received mitigation evidence: Amaral's youth, immaturity, mental health issues (ADHD, intermittent explosive disorder, bipolar, conduct disorder), and significant influence/sexual abuse by Greg Dickens; the judge expressly considered Amaral's age and immaturity.
- In 2012 Amaral sought post‑conviction relief under Ariz. R. Crim. P. 32.1(e), arguing that later scientific advances about juvenile brain development (relied on in Roper, Graham, Miller) were "newly discovered" material facts that would have changed his sentence.
- The trial court dismissed the petition for lack of a colorable claim; the court of appeals affirmed, reasoning the scientific advances did not exist at sentencing.
- The Arizona Supreme Court granted review to decide whether later juvenile‑development science qualifies as newly discovered evidence warranting an evidentiary hearing.
Issues
| Issue | Amaral's Argument | State's Argument | Held |
|---|---|---|---|
| Whether advances in juvenile psychology/neurology are "newly discovered" material facts under Rule 32.1(e) | Scientific findings post‑sentencing show juveniles are less culpable and thus probably would have changed sentence | The behavioral characteristics of juveniles were known and were considered at sentencing; the later science does not create a newly discovered condition | Held: Not newly discovered; juvenile status and its behavioral implications were known and considered at sentencing |
| Whether Amaral alleged facts that probably would have changed his sentence (colorable claim) | The new research (Roper/Graham/Miller) undermines penological justifications for harsh juvenile sentences and would likely have altered sentencing | Even assuming research is accurate, it supplements preexisting knowledge and would not probably have changed outcome because judge already considered youth/immaturity | Held: Amaral did not present a colorable claim; no evidentiary hearing required |
| Proper standard for entitlement to a Rule 32 evidentiary hearing | (Implicit) A showing that the new facts might have changed outcome is sufficient | The proper standard is that the alleged facts probably would have changed the verdict/sentence | Held: Court clarifies standard—must show facts which, if true, probably would have changed outcome (not merely might) |
| Application of Bilke (newly recognized condition) to juvenile‑development science | Amaral analogizes to Bilke, where a later PTSD diagnosis was deemed "newly discovered" | State distinguishes Bilke: PTSD was an unrecognized condition at trial; juvenile characteristics were recognized and considered | Held: Bilke is distinguishable; Bilke involved an existing but unrecognizable condition—Amaral's juvenile status was known and considered at sentencing |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles categorically exempt from death penalty; scientific studies confirm known differences between juveniles and adults)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for nonhomicide juvenile offenders violates Eighth Amendment)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles violates Eighth Amendment; distinctive attributes of youth reduce penological justifications)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller announced substantive rule with retroactive effect; children constitutionally different)
- State v. Bilke, 162 Ariz. 51 (1989) (post‑trial diagnosis of an unrecognized condition may be newly discovered evidence)
- State v. Jeffers, 135 Ariz. 404 (1983) (definition and effect of a colorable claim in Rule 32 context)
- State v. Gutierrez, 229 Ariz. 573 (2012) (standard of review for denial of Rule 32 petition; summary dismissal when alleged facts would not probably change outcome)