Arizona Supreme Court
State of Arizona v. valencia/healer
December 23, 2016
Summary
The court held that Miller, as clarified by Montgomery, constituted a significant and retroactive change in constitutional law under Arizona Rule of Criminal Procedure 32.1(g). Because the petitioners received natural-life sentences for murders committed as juveniles, they were entitled to evidentiary hearings to determine whether their crimes reflected irreparable corruption or transient immaturity. The court reversed the trial courts, vacated the court of appeals' opinion, and remanded for further proceedings.