Israel Naranjo v. Hon. sukenic/state of Arizona

Summary

The court held that the post-conviction court properly ordered disclosure of materials concerning trial counsel's interviews with three family members because the ineffective-assistance and intellectual-disability claims supplied good cause under Rule 32.6(b)(2). By asserting ineffective assistance, Naranjo waived attorney-client privilege to information necessary for the State to rebut the claims, although the court did not resolve who held any work-product privilege. The court affirmed the disclosure order and remanded for proceedings consistent with specified redaction, privilege-log, and in-camera-review procedures.