On Wednesday, the Supreme Court decided Cruz v. Arizona. The posture here is a bit complicated. Simmons v. South Carolina (1994) held that during sentencing, the judge must notify the jury that a defendant would be ineligible for parole. For some time, the Arizona courts held that the state's sentencing scheme did not trigger application of Simmons. In Lynch v. Arizona (2016), the Supreme Court summarily reversed the Arizona Supreme Court, holding that the failure to apply Simmons was an error.
Cruz filed a motion for state postconviction relief based on Arizona Rule of Criminal Procedure 32.1(g). Cruz argued that Lynch caused "a significant change in the law that, if applicable to the defendant's case, would probably overturn the defendant's judgment or sentence." The Arizona Supreme Court, relying on Rule 32.1(g), held that Lynch did not cause a "significant change in the law."
On appeal, the United States Supreme Court held that the Arizona Supreme Court was wrong about Lynch, which did cause a "significant change" in the law. Moreover, the state court's interpretation of its rule could not be deemed an "adequate and independent state-law ground for the judgment." (Abbreviated in the lingo as an AISG) The vote here split 5-4. The Chief Justice and Justice Kavanaugh allowed Justices Sotomayor, Kagan, and Jackson to form a majority opinion. Justice Barrett wrote a dissent, which was joined by Justice Thomas, Alito, and Gorsuch.
