State of Arizona, Respondent v. Gregory Nidez Valencia Jr., Petitioner; State of Arizona, Respondent, v. Joey Lee…

Summary

The court held that the constitutional rule governing juvenile life-without-parole sentences constituted a significant change in law under Arizona’s post-conviction-relief rule and applies retroactively. Because the petitioners made colorable claims that their crimes might reflect transient immaturity rather than irreparable corruption, they were entitled to evidentiary hearings, though they were not automatically entitled to resentencing. Justice Bolick, joined by Vice Chief Justice Pelander, concurred while criticizing the constitutional rule’s expansion and its practical consequences.