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Cruz v. Arizona

Cruz v. Arizona is a case at the Supreme Court that argues for changing the post-conviction decision of John Montenegro Cruz being sentenced to death by the Arizona courts (Hoag-Fordjour, 2022). The case is John Montenegro Cruz v. State of Arizona, 21-846. Cruz had several of his appeals in the Arizona Supreme Court, and his petition was denied at the U.S Supreme Court. Cruz and his legal team have argued that the jurors during his conviction were never informed that he was not eligible for parole after being sentenced to life in prison. The only option was for him to be sentenced to death as a danger to society. With that kind of information to the jurors, Cruz believes that their decision would have been different, and they would have opted for life in prison for him.

The jury deliberated after the case against Cruz in 2005 and returned with a death sentence against Cruz, who was convicted of committing a first-degree capital murder in 2003 (Gresko, 2022). The law in Arizona states that capital offenders are ineligible for parole if sentenced to life in prison. Cruz’s defense counsel wanted the court to inform the jury of this law before they decided on the matter so that he could be spared from the death penalty. Failure to inform the jury and give them options resulted in Cruz getting the death penalty. Some jurors commented on the case and said they wanted to be lenient, but they were not given any other options while deciding to return the death penalty against the offender (Hoag-Fordjour, 2022).

The decision by the Arizona court denying the jury all the facts is the basis for which Cruz has filed a case in the Supreme Court. Since the U.S Supreme Court had already affirmed the decision by the Arizona Supreme Court the first time, Cruz filed a petition for post-conviction relief; only a significant change of law would help in changing his death sentence (Oyez, n.d). The opportunity for Cruz was in a 2016 case, Lynch v. Arizona, whereby the U.S Supreme Court sensitized to Arizona the need to comply with Simmons (Gresko, 2022). The convicted, John Montenegro Cruz, argued that the jury was not provided with all the facts, and in them, choosing life imprisonment over the death penalty would mean he would be in prison for life without parole.

The Cruz v. Arizona case is essential to many people in the justice system, including lawmakers, judges, lawyers, prosecutors, and inmates. Over the years, several inmates have been put on death row by jurors who had not been informed of the no-parole rule for capital offenders. The Simmons case was to be the law of the land, as shown by the Supreme Case decision of 1994 and the Lynch case of 2016. Cruz’s case may favor him during decision-making as it is seen as an error of the Arizona Court not to apply the Simmons during the conviction of Mr. Cruz.

According to Gresko (2022), in the 1994 case Simmons v. South Carolina, the jury involved with the case must be duly informed that choosing life imprisonment over a death sentence does not mean the possibility of parole for the offender. Cruz’s lawyer accuses the Arizona Court of not adhering to Simmons, which makes it the only state in the United States of America to do so despite the rest of the states following the rule. The decision by the U.S Supreme Court will impact many current and future capital offenders and also may influence Arizona into the death penalty and following Simmons. The Supreme Court Judges will have to look at past cases like Simmons and Lynch, the state and federal law, and the kind of impact that a decision of this magnitude will have on the country and society.

In the Arizona Court, Rule 32.1g states that “grounds for relief is if there has been a significant change in the law that, if applicable to the defendant’s case, would probably overturn the defendant’s judgment or sentence;” (Casetext Scope of Remedy, Ariz. R. Crim. P. 32.1). Therefore, Cruz was justified to file a case against Arizona for neglect in applying Simmons while he was being convicted. It was his federal right to be convicted under the law without the interference of anybody in the court. According to Cruz’s lawyer, the Arizona Judge did not apply the Simmons law while Cruz was convicted. Cruz is filling a relief case against Arizona since he believes the law significantly changed when the ruling was made during the Lynch v. Arizona U.S Supreme Court case (C-Span, 2022).

The Simmons v. South Carolina Supreme Case decision became a cornerstone for the many people who have been convicted while their parole ineligibility was not mentioned to the jurors. The Federal rights of Cruz and several other death row inmates are considered to have been neglected by the Arizona Courts. The U.S Supreme Court is the highest in the United States, and its law is meant to be recognized within every state. Since the rest of the states apply Simmons in their convictions, Arizona is the only state not to follow the Supreme Court’s directive.

Hoag-Fordjour details in her October 2022 article about the case that Amici curiae, friends of the court, filed six briefs; out of those, five support Cruz while one supports Arizona. Some of the briefs provided details on discrimination against Cruz due to racial bias and his potential threat to others. Cruz being Mexican-American may have been viewed as a threat, as is the case with being African –American in the judicial justice system. The rest of the brief majors their files on the court procedure and whether the Arizona court was fair to Cruz by not applying Simmons during his case. The U.S Supreme court will still respect the state laws while making a ruling on the federal rights that were obstructed. As already established by the Arizona court, he is guilty, but his federal rights have to be respected too.

Most of the U.S Supreme Court judges may be leaning toward Cruz getting a new penalty phase for his trial (Gresko, 2022). The Judges will vote on their decision and make a ruling either upholding the ruling of the Arizona Supreme Court or respecting the decision of the previous case of the U.S Supreme Court, which upheld Simmons if there is no reasonable doubt that the jurors were not informed of his non-eligibility for parole if sentenced to life in prison. The ruling will shake up some cases in Arizona and may even get the state to abide by the Simmons and apply it in their convictions.

In conclusion, according to the facts provided by Cruz and his legal team, it is fair to say that Cruz deserves another conviction phase of the trial with a familiar jury on all points. The outcome of the case will favor Cruz, and that will mean the rest of the prisoners on death row who had similar issues with their conviction will get to be heard. Several of these prisoners on death row will succeed in their cases, which would have been pioneered by Cruz and his quest for justice and respecting the rule of law. In another turn of events, the Supreme Court may decide against Cruz and uphold the decision of the Arizona Supreme Court. Whatever the outcome may be, it will affect the lives of several people currently and in the future.


C-Span (2022). Cruz v. Arizona Oral Argument [Video File]. Retrieved from:

Casetext (2022). Rule 32.1 – Scope of Remedy, Ariz. R. Crim. P. 32.1. retrieved From:

Gresko, J. (2022). High Court told jurors were misled in Arizona death row case. Retrieved from:

Hoag-Fordjour, A. (2022). A due-process claim from a man on death row hinges on how the justices view an Arizona procedural rule, SCOTUS blog Retrieved from:


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