State of Arizona, Appellee v. Cesar Montes, Appellant

Summary

The court held that the Legislature constitutionally enacted SB 1449 to apply the self-defense burden-of-proof amendment retroactively to specified pending criminal cases. The statute did not usurp judicial power, disturb vested rights, overrule a judicial decision, or prescribe factual findings in pending cases. The court also held that SB 1449's nonoperative statement of legislative purpose did not undermine the operative retroactivity provision, and it reversed Montes's convictions and sentences for further proceedings.