State of Arizona, Petitioner v. Kevin Artice Miles, Respondent.

Summary

The court held that evidence of diminished capacity and voluntary intoxication may be considered when determining whether a major participant in felony murder subjectively acted with reckless indifference to human life under the Eighth Amendment death-eligibility framework. Because the applicable version of the voluntary-intoxication statute did not bar such evidence from addressing that sentencing inquiry, the PCR court properly commuted Miles's death sentence. The court did not resolve whether Rule 32.1(h) independently permits relief based on newly presented mitigation evidence. The opinion contains no separate opinions for purposes of this extraction.