Arizona Supreme Court

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

December 23, 2016241 Ariz. 206

Summary

The court held that the constitutional rule governing juvenile life-without-parole sentences was a significant change in law that applies retroactively, so the petitioners stated colorable claims for post-conviction relief. It reversed the summary denials and remanded for evidentiary hearings to determine whether their crimes reflected irreparable corruption or transient immaturity. Justice Bolick, joined by Vice Chief Justice Pelander, concurred fully but criticized the broader constitutional reasoning and practical consequences underlying the governing rule.