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's death sentence after a federal habeas court identified an error in the prior consideration of his mitigating evidence. It held that the jury-trial rule for capital aggravating factors did not apply because the convictions and qualifying aggravating factors were final before that rule was announced, and it gave little mitigating weight to Styers's PTSD because the evidence did not connect it to the crime. The court therefore affirmed the death sentence. Hurwitz, Vice Chief Justice, dissenting, would have required a new jury proceeding on at least one aggravating factor because the federal habeas proceedings prevented the sentence from being final.