Arizona Supreme Court

State of Arizona, Appellee v. James Lynn Styers, Appellant

July 1, 2011227 Ariz. 186

Summary

The court conducted a new independent review of Styers' death sentence after federal habeas proceedings identified an error in the court's prior consideration of his PTSD mitigation. It held that the later jury-trial rule for capital aggravating factors did not apply because Styers' case was final before that rule was announced, and it treated the previously affirmed aggravating factors as established. Although the court considered Styers' PTSD, it gave the condition little weight because the evidence did not connect it to the planned and deliberate murder, and it affirmed the death sentence. HURWITZ, Vice Chief Justice, dissenting, would have required a new jury proceeding on at least one aggravating factor because the renewed review constituted direct review.