State of Arizona, Appellee/cross-Appellant v. Joel Randu Escalante-Orozco, Appellant/cross-Appellee

Summary

The court affirmed Escalante-Orozco’s convictions and prison sentences but vacated his death sentence and remanded for a new penalty phase. It rejected challenges concerning intellectual-disability procedures, competency, custodial statements, jury selection, DNA and third-party-culpability evidence, prosecutorial conduct, and the sufficiency of the guilt-phase evidence. The court held that the State placed future dangerousness at issue and that the jury should have been told Escalante-Orozco was ineligible for parole. It also held that a penalty-phase jury may determine intellectual disability as a bar to execution. No separate opinions were filed.