Arizona Supreme Court
State of Arizona, Appellee v. Shawn Ryan Grell, Appellant — Bales, J., Concurring
January 9, 2013231 Ariz. 153
Summary
Justice Bales concurred in the court’s decision to sentence Grell to natural life because independent review established by a preponderance of the evidence that Grell had intellectual disability, which constitutionally barred execution. He also observed that the trial court could have reconsidered its earlier pretrial determination in light of extensive additional evidence and identified unresolved procedural questions for future cases.