Carlos Cruz v. Hon. blair/state of Arizona

Summary

The Arizona Supreme Court affirmed pretrial orders excluding expert and lay testimony about Cruz’s intellectual disability and limiting him to two lay witnesses. The court held that intellectual-disability evidence was irrelevant to whether Cruz voluntarily acted or was physically capable of performing legally required caregiving acts, and that admitting it would improperly implicate mens rea and confuse the jury. The court permitted otherwise admissible behavioral-tendency or observation evidence, including testimony about observed limitations, but prohibited linking those tendencies to intellectual disability. It also held that the witness limitation did not violate due process because the proposed testimony was dated and cumulative.