Archive for the ‘Arizona Statutes’ Category

Wasted Anger

Friday, June 18th, 2010

I keep thinking about something I saw in court a little while ago. The judge, a former sex crimes prosecutor with a temper that makes her unpopular among attorneys on both sides, decided to take a page out of Judge Judy’s playbook and dramatically castigate a defendant at sentencing.

“I’m very sorry, and I will not let it happen again,” the defendant said. The judge attacked before he could even finish, asking him why things were going be different this time. She threw his priors at him when he tried to explain. She rubbed in the fact he was on probation when it happened. She expressed her disbelief by rolling her eyes, and she made sarcastic remarks. His pleas fell on deaf ears. She beat him up, on the record and in a standing-room-only courtroom. He was mortified.

I imagine that what I saw was her version of tough love. She sentenced him leniently overall, so I think she was probably just hoping to scare him straight. I’m sure she thought her abuse, which she condescendingly heaped on this man who was a decade or more her senior, was for his own good. I wasn’t impressed.

I’ve seen her do things like that before, but I haven’t posted about it. The reason this case has stuck in my head is because of the crimes for which she was sentencing that poor man.

He was convicted of breaking into his own shed, which someone else was renting from him. The tenant quit paying and put a lock on the door. He destroyed the lock and entered without having gone through the appropriate legal channels. No one in the room, not even the prosecutor, seemed to dispute what happened.

Even worse, he was also on probation for theft of protected native plants, a class 4 felony. In Arizona, you see, it is a felony to knowingly remove or destroy any protected native plants from private or state land without the express consent of the landowner. Don’t believe me? Have a look at A.R.S. § 3-932. If the plant has a value greater than fifteen hundred dollars, it’s the same class of crime as nonresidential burglary (the charge in his other case) or aggravated assault causing temporary but substantial disfigurement. I think he dug up a cactus.

The judge wasted her anger. The guy’s a repeat offender, but look at the offenses. Didn’t she think for one second that it was ridiculous making an example out of a guy who took a cactus and tried to enter his own shed? He’s already at least a two-time felon. Although it’s for dumb reasons, employers probably don’t care. He’s going away for a relatively long time. Her scolding had no real effect.

I never like it when she goes off on defendants. At best, it plays to the worst in those who watch. It appeals to our desire to shame and ostracize others. I don’t believe for a second that it’s for their good; it’s because it makes us feel better about ourselves in some sick way.

If we lived in a place where laws and punishment had any rational relationship to morality or what offenders actually deserve, maybe there might be someplace in the courts system for something like what I saw. I still doubt it. Sadly, we don’t live in such a place.

Senate Bill 1070

Friday, May 7th, 2010

Everyone has an opinion about Arizona’s Senate Bill 1070. Unless you’ve been living under a rock, you probably love it or hate it. You may have a strong opinion about it even if you have no clue what it says. If so, you aren’t alone.

S. B. 1070 makes it so the government can’t create a policy limiting the enforcement of federal immigration laws. If any part of the government does make a policy restricting enforcement of federal immigration laws, citizens have standing to sue. If they win, they get court costs and attorney fees.

This doesn’t mean an officer will be sued just for not arresting a particular person or group of people. There will have to be a policy, not just one officer failing to do something, in order for that to happen. Also, unless an officer acted in bad faith, his agency will indemnify him for fees and costs, including attorney fees. People won’t be suing the cop personally.

There is a civil penalty of $1,000 to $5,000 for each day the policy remains in effect after the action is filed, and that money goes to a DPS fund for, among other things, immigration enforcement. The law creates something called the “gang and immigration intelligence team enforcement mission fund.” To repeat, the big penalty money doesn’t go to the plaintiff. Only the lawyers and the DPS fund will likely get rich from the law.

S. B. 1070 also makes it so no part of the government can be prevented from sharing immigration information with other parts of the government for all kinds of reasons. That includes when the government is trying to determine eligibility for anything any part of the state or federal government offers, whether that means applying for welfare or even getting a driver’s license. That also applies when the government is verifying residency, confirming the identity of someone who is detained, or making sure someone is a registered alien under federal law.

Finally, the law requires that employers not only e-verify every employee, but also keep a record of the verification for the entire employment or 3 years, whichever is longer. Employers who hire undocumented immigrants have an affirmative defense of entrapment if they’re set up by authorities (which I can assure you will happen), but like with any entrapment defense in Arizona, they must admit to the offense, bear the burden of proof by clear and convincing evidence, and must among other things show they weren’t predisposed to commit the crime in the first place. It’s about as tough an affirmative defense as you could imagine. I’ve never used it in a criminal case, nor have I ever seen a criminal defense lawyer use it in a criminal case.

The bill wouldn’t just create new government policies. It creates all kinds of new government obligations and powers too. Under the law, if an officer makes lawful contact with a person, and if after that the officer develops reasonable suspicion that the person is an undocumented alien, the officer must make a reasonable attempt to determine the person’s immigration status if practicable. They have to verify it with the feds. This requires that officers do things they might not have done before, but it does not explicitly give them a new way to stop people.

The bill also says that, if an officer has reasonable suspicion someone is breaking the human smuggling law and breaks a civil traffic law, he can lawfully make a stop. Officers can already make a stop after seeing a traffic violation, so that portion may be largely pointless, depending on how the courts interpret it.

Officers can also already arrest someone who commits a crime in front of them, so the part of the bill saying officers can make a warrantless arrest if someone has committed a crime that makes them removable isn’t that revolutionary either. Again, that may depend on how the courts read the law, and as an aside, good luck teaching cops which offenses make people removable. The quick reference chart Arizona defense attorneys use to figure that out is 184 pages long, and most attorneys consult an expert on top of that. I do.

Perhaps the biggest change is the part of the law saying that, if an undocumented immigrant breaks any law (even a traffic law), when his or her sentence is done (whether the sentence is a fine, probation, or incarceration), he or she will be brought to ICE. That means we could theoretically be incarcerating undocumented immigrants the moment they pay their photo radar ticket.

Another huge change is the part saying law enforcement can take an undocumented immigrant who is in their custody to a federal facility even if it means officers must leave their jurisdiction to do so. We may have cops driving all over the state getting undocumented immigrants to federal immigration facilities.

Finally, S. B. 1070 creates all kinds of new crimes. Just like a bill I discussed over a year ago, it makes it so an undocumented alien is guilty of trespassing simply by virtue of being in Arizona. The way to determine someone’s immigration status is through an officer federally authorized to verify it or by communicating with the feds. Someone convicted of this new crime must serve the entire sentence without any kind of early release and must pay jail costs and an assessment of $500 for the first violation or $1000 for a second. The assessment goes to the DPS fund mentioned above.

It’s a class 1 misdemeanor just to be here without papers. It’s a class 3 felony if you have in your possession dangerous drugs, precursors for making meth, a deadly weapon or dangerous instrument, or property used for terrorism. It’s a class 4 felony if you’ve violated the law before or have been removed in the past 5 years.

The law also makes it a crime to stop in your vehicle in order to hire someone to work at a different location if you impede traffic, or to get in a vehicle in order to be hired to work at a different location if that impedes traffic. Furthermore, it’ll be a crime for an undocumented immigrant apply for work, solicit work in public, or work as an employee or independent contractor. Those are all class 1 misdemeanors.

“Solicit,” by the way, is defined as “verbal or nonverbal communication by a gesture or a nod that would indicate to a reasonable person that a person is willing to be employed.” Careful not to nod at your ride when they pick you up to carpool home, and never meet your ride at Home Depot.

If you know or recklessly disregard the fact someone is undocumented, it will also be a crime for you to do the following to them: transport, move, attempt to transport or move, conceal, harbor, shield, attempt to conceal or harbor or shield, or encourage or induce to come here or reside here. Don’t call up your friend in Mexico and suggest he come to Arizona to visit or live with you unless you know he has the right papers. You could be charged with a class 1 misdemeanor, and there’s a $1,000 fine. If you’re inviting ten or more of your undocumented alien friends, it’s a class 6 felony.

Finally, the bill will make it so your vehicle is subject to immediate immobilization or impound for pretty much anything. The government just loves taking people’s cars.

Paul Kennedy at The Defense Rests summed up a lot of what I was thinking in this post. If the bill goes ahead as planned, Hispanic citizens will be stopped, detained, and accused of crimes at an alarming and unprecedented rate. Although the bulk of this law will fall on them, no race is safe. People of all ethnicities will soon find themselves being deported after getting stopped for a cracked windshield or expired tags.

I have no faith in Arizona’s courts to strike down S. B. 1070. I have no faith in the federal courts to strike it down either. I see most if not all of it as clearly being preempted, but any judge with political ambitions won’t want to touch it with a ten foot pole. According to at least one poll, most Americans seem to support the bill. I imagine it will end up standing at least in part, and any little part of it that does stand will probably be significant enough to make life very different for a huge number of good people here in Arizona.

In this post and this post, Rick Horowitz at Probable Cause really hits on exactly where I think Arizona is going. If we aren’t already one, we are rapidly becoming a police state. It’s sad that Rick, a California lawyer, would write two posts about becoming a police state and Arizona would come up in both.

The road we’ve taken is slow. Courts have allowed roadblocks. They’ve allowed pretextual stops. The Fourth Amendment has been swallowed by exceptions, one at a time. The erosion of our rights has been gradual, and it’s been justified by our desire to stop things most people fear: drugs, DUI, property crimes, violent crimes. We wanted to get the bad guys, so we gave up our rights.

Now, the legislature has created a whole new class of bad guys. They’re your neighbors. They’re your friends. If you aren’t a bad guy yet, you’ll be next. Something you do or even a fundamental part of who you are will soon be outlawed.

People who loved seeing rights disappear when they thought the constitution just shielded criminals are now going to wish they had those lost rights back. People never expect that they’ll become criminals. Roadblocks and pretextual stops take on a new light when they end up being primarily effective not at preventing DUI or finding drugs, but at catching people of a certain race.

I hate the bill. I think it’s racist. If it passes constitutional muster, I think it will keep officers from solving real crimes. I think it will be expensive and generally ineffective at its desired purpose. I can only hope the courts somewhere along the way stand up and do the right thing. If not, I wonder what will happen to the federal immigration system.

Imagine the lines of people waiting to be taken into federal custody, deputies waiting by their side. Imagine our immigration courts trying to deal with the influx. I always say this with respect to drug prohibition, but it may be even more appropriate here: what if we won this new war? Can you imagine filling our federal system with half a million new, nonviolent offenders? That’s just in Arizona.

If you like the bill, I doubt I’ll be able to change your mind by espousing the virtues of liberty or racial tolerance. I do, however, suggest one thing. Before you pass final judgment on the bill, see what it costs. The price tag of turning thousands and thousands of otherwise law-abiding people into criminals may change your mind.

The Price of Being Right

Monday, April 12th, 2010

Arizona’s Revised Statutes are filled with mandatory sentencing provisions. For instance, A.R.S. 13-703 says that a repetitive offender in “category three,” someone who has been convicted of a felony and has two or more historical prior felony convictions, “shall be sentenced” within certain sentencing ranges. The range for a category three offender convicted of a class 2 felony is 10.5 years to 35 years.

A.R.S. 13-704 contains another mandatory sentencing scheme. A “dangerous offense” is one “involving the discharge, use or threatening exhibition of a deadly weapon or dangerous instrument or the intentional or knowing infliction of serious physical injury on another person.” If someone is convicted of a “dangerous” class 2 felony, the statute says that he or she “shall be sentenced” to a term of imprisonment between 7 and 21 years.

When I first started out, it was tough for me to wrap my head around conflicting mandatory sentencing provisions. That was because I hadn’t seen how it worked in practice. What happens when someone is convicted of a class two dangerous offense and also has two historical priors?

The practical reality of the matter is that it will almost never be an issue. The state must allege and prove at trial that an offense is repetitive or dangerous in order for a defendant to be sentenced pursuant to one of those statutes. If the state wants to make sure the defendant receives a sentence in the harshest mandatory sentencing range, it can just withdraw the other allegations. Pretty much anyone with a little bit of experience in criminal laws know the longest sentencing range is going to apply, but many people don’t know why.

I recently watched a settlement conference for a defendant who faced two allegations with conflicting mandatory sentencing ranges. The defense lawyer had clearly read both statutes in detail and was very proud of himself for figuring out a clever argument about why the statute containing the lesser range would govern if the state proved both allegations. The judge, who wanted to advise the defendant about what he potentially faced if he lost at trial, obviously did not understand the defense lawyer’s argument. He knew the harsher range applied, but it was obvious he didn’t know why.

The defense lawyer was right from a purely legal standpoint. If the state was stupid enough to go through with the whole trial and prove both allegations, the defendant would likely have to be sentenced inside the lesser of the two ranges. However, the judge’s advice about what the defendant faced if convicted at trial was far more accurate.

The defense lawyer ranted and raved, wanting everybody in the courtroom to see just how smart he was. It was uncomfortable. I think that every lawyer in the courtroom knew that the defense lawyer was right. Kinda. They also all knew the judge was wrong. Kinda.

The hearing ended with the judge advising the client of the stiffer prison range and the defense attorney making a record about how he disagreed. If the prosecutor didn’t previously know to drop the other allegation to increase the defendant’s mandatory minimum, he sure knew after that settlement conference.

That hearing reminded me that making sure everyone knows you’re right often isn’t worth it. It’s an important lesson for a lawyer to learn.

Judges Aren't Always Right

Monday, October 12th, 2009

A week or two ago, I saw a judge make a ruling completely contrary to the law. It happens, but usually not so obviously.

The judge was hearing a number of pleas at once. Two of the defendants were in custody and pleading to aggravated DUI. Pursuant to A.R.S. § 28-1383(D) and (E), certain types of felony DUI require that a defendant spend a certain amount of time in prison before being placed on probation.

In Arizona, prison and jail are different. Jails are run by counties and cities, and felony defendants spend their time in county jail pending resolution of their criminal matters. Prisons are run by the state. You can only go to prison if you are sentenced.

Both of those pleading defendants were in custody and had pleas stipulating to probation with the mandatory prison required by the statute. Both had pleas giving them credit against the mandatory prison term for the time they spent in jail prior to sentencing.

The judge indicated he could not give them credit for jail served because the statute specifically said the time had to be “in prison.” On its face, that seems to be what the statute requires. It isn’t, and the judge was wrong.

A.R.S.§ 13-709(B) provides that “[a]ll time actually spent in custody pursuant to an offense until the prisoner is sentenced to imprisonment for such offense shall be credited against the term of imprisonment.” There are cases from each division of the Court of Appeals of Arizona holding that DWI statutes do not preclude credit for presentence incarceration time. Some are still good law and over a decade old (for the Arizona lawyers reading this, check out State v. Nihiser, 191 Ariz. 199 from Division Two in 1997 and State v. Mathieu, 165 Ariz. 20 from Division One in 1990).

The judge told the lawyers he would not give their clients the presentence incarceration credit required by the pleas, and neither attorney was able to convince him he was permitted to do otherwise. Each matter was continued for a week or two so the attorneys could work out an agreement that fit the judge’s concept of what the law required.

Hopefully, the attorneys have already brought to the judge’s attention the statute and cases I mentioned above. I sent one of them the cites after the hearing, and I hope both clients enter those pleas again as soon as possible. I hope the judge has realized he was wrong. There’s no way he could have been right.

Here’s what I really wonder: when the judge realizes his mistake, if he hasn’t already, will he feel bad? What if one of those defendants ends up serving an extra week or two because of the continuance he forced based on incorrect legal principles? Will he only be embarrassed about being wrong, or will he feel guilt about mistakenly depriving two people of their freedom?

The Motorcycle That Could Not Be

Friday, September 11th, 2009

I recently finished working on a pro bono forfeiture case. The short story is that a guy puts a new engine and forks on a 1970s Harley Davidson in California in 1991. He registers it in California, and they give it a new VIN because the new motor serial number doesn’t match the frame. This is a common practice for motorcycles.

My client enters the picture in 1992 or 1993, when he buys the motorcycle. He registers it in California and operates it for years with no issues. He moves to Massachusetts and registers it with no problem. In 2004, he moves to Arizona to be closer to his children and grandchildren.

When he takes the bike to the Arizona MVD in 2007 (he didn’t ride it for a few years), the inspection officer notices the California VIN is different from the manufacturer VIN code and wants the bike to be checked out by a specialist. My client complies and brings the bike back for another inspection a few days later. This specialist is an Arizona Highway Patrol officer, and he decides the bike may be contraband and seizes the motorcycle.

When I met the client, the motorcycle had been in impound for months. I was confident that I could get the motorcycle back; after all, my client had a mountain of evidence proving that he bought the motorcycle in good faith and that California had applied a new VIN to the motorcycle. Other states would be required to recognize that VIN, right? Also, it would be pointless to take away a man’s motorcycle of over a dozen years, right? Not in Arizona.

The contraband statute is so incredibly broad that the Judge ordered the motorcycle be destroyed. The state argued two things: 1) that the California VIN was invalid because it altered the manufacturer’s VIN, and 2) that the forks may have been stolen in the 1980s.

Unfortunately, the burden of proof is on the owner to prove the state is wrong. California destroys MVD records after five years when no foul play is suspected, so it was impossible for my client to obtain the original California records. Ironically, that was due in part to the fact no foul play was suspected (in my opinion, correctly so).

We argued that California did its own investigation twice (when the new VIN was applied and when the bike was transferred to my client), and we brought up the fact Massachusetts had no problem with the motorcycle. How could Arizona, after nearly twenty years, be in a better position to determine if parts on the bike were stolen? Another frustrating aspect of the case was that everyone agreed that Arizona does things no differently when applying a state VIN to a vehicle.

After a trial and many motions, including a motion to reconsider that almost turned the tide, the state convinced the judge that we didn’t prove the forks weren’t stolen and didn’t prove the California VIN was sufficient. How could we? How does someone prove motorcycle forks weren’t stolen? Prove to me that your thirty year old lawnmower wasn’t stolen. You can’t. A receipt could be for an identical (but different) set of forks.

There’s a reason why the state should always have the burden of proof. They have massive resources. It’s the state’s courts.

In the end, the State of Arizona destroyed a man’s prized possession not because it was dangerous, not because it was going to be returned to the rightful owner, not because the man had done anything wrong, and not because the motorcycle had been used in a crime.

I think the implications of the ruling are terrifying.

Arizona DUI Stupidity

Tuesday, July 7th, 2009

Imagine you’re sitting in the comfort of your own home, enjoying a glass of fine single barrel Kentucky straight bourbon whiskey. It’s about midnight, and you’re on your third or fourth when you hear the back window of your home shatter. You can hear that someone is trying to break into the house, and you run to call 911. As you frantically rush through the house, you see someone breaking in through the front window as well. You have no time to think, and not knowing what else to do, you swing open the door leading to your garage and jump in your car. You lock your doors, fire up the engine, open the automatic garage door, and speed off while calling the police.

Congratulations, you just escaped a very dangerous situation. You’re safe, but just for a little while. A few blocks from your home, a friendly law enforcement officer notices your excessive speed and pulls you over. When he walks up to the driver’s side window, he sees you’re a wreck. You’re sweaty, shaking, and can’t think straight. You don’t make any sense, constantly rambling about intruders. He notes your bloodshot, watery eyes, your slurred speech, and smells a moderate odor of alcohol. Don’t they always? He doesn’t care about your crazy burglary story because he’s heard every imaginable drunk driving sob story a million times. He wants to know how many you’ve had. He wants you to do some tests. Because you’re so flustered, you forget to ask for your lawyer. You do what he asks. He eventually takes you to the station, and you submit to a blood test.

I’ve got some bad news for you. You’re going to get a DUI. The courts won’t care that you can prove your windows were broken and your home was burglarized. It doesn’t matter that you have 911 in your call history, left your garage door wide open, and that there’s an ongoing police investigation about the burglary of your home. It won’t matter if they catch the guys who did it and you’re the named victim in the case against them.

Here’s the problem: there is no necessity defense to DUI in Arizona. In fact, to my knowledge, there is no type of DUI justification defense whatsoever in Arizona. That’s explained very clearly in State v. Fell, 203 Ariz. 186, 52 P.3d 218 (App. 2002), a Court of Appeals of Arizona, Division Two case that tells us why justification defenses do not apply to DUI.

State v. Fell doesn’t have the facts I just described, but the facts of the case do make me feel bad for the defendant. She was assaulted by her husband, who left the house. Fearing for her safety if her husband returned, she left. She was eventually stopped, arrested, and charged with DUI. She wanted to use as a defense “the fact that she had necessarily driven away from her home because of concern for her safety,” and the trial court let her. However, the state got a stay before trial and filed a special action, which it ultimately won.

The reason she didn’t get to employ a necessity defense, the same reason you won’t be able to use a justification defense, is because the DUI laws are found in Title 28 of the Arizona Revised Statutes, while the justification defenses are found in Title 13 of the Arizona Revised Statutes. A.R.S. 13-417 says that “[c]onduct that would otherwise constitute an offense is justified if a reasonable person was compelled to engage in the proscribed conduct and the person had no reasonable alternative to avoid imminent public or private injury greater than the injury that might reasonably result from the person’s own conduct.” It’s found in Chapter 4, “Justification,” which is found in Title 13. Title 13 is the criminal code. Also in Chapter 4 of Title 13 is A.R.S. 13-401, entitled “Unavailability of justification defense; justification as defense.” That statue provides that “justification, as defined in this chapter, is a defense in any prosecution for an offense pursuant to this title.” Unfortunately, Arizona’s DUI laws are all found in Title 28 along with other laws involving transportation.

State v. Fell isn’t a long opinion, but it’s long enough to pretty thoroughly piss me off. Even the way it states the facts of the case is irritating. The court admits the facts of the case were undisputed, yet it says the defendant’s husband “allegedly assaulted her.” I suspect that, if you appealed based on the facts I gave you above, the court would say your home was “allegedly burglarized.”

The defendant argued that the court should look at A.R.S. § 13-102, which provides that Title 13 “shall govern the construction of and punishment for any offense defined outside this title.” Sounds good, right? Justification defenses should apply to Title 28 offenses, right?

No such luck. The court decides the issue at hand doesn’t involve “the construction of” or the “punishment for” a DUI offense. I guess I can understand why they think that deciding whether to apply a defense might not be considered construction or punishment, but it irritates me. Arizona courts use A.R.S. § 13-102 to apply Title 13 sentence enhancement provisions to Title 28 felonies, but they won’t use it to apply Title 13 defenses to Title 28 felonies. I understand a sentence enhancement is pretty clearly “punishment for” a non-Title 13 offense, but I feel like it’s another example of courts interpreting statutes one way when they help the state and another way when they help defendants.

The court decides that the words “this title” reflect a clear legislative intent to limit application of the justification defenses to Title 13 and says that “no further inquiry is required.” The court ignores the rule of statutory construction called the rule of lenity because the statute is clear. Then, it applies the rule of statutory construction called inexpressio unius est exclusio alterius to decide that, because A.R.S. § 13-401 doesn’t list non-Title 13 offenses like DUI, the legislature did not intend justification defenses to apply to them. The court wasn’t impressed with the out-of-state authority the defendant cited, and it explained that Arizona has no common law defense of necessity. The court concludes that a DUI defendant can’t argue necessity.

The biggest frustration in all this is that I can’t say the case was wrongfully decided based on the text of the statutes. The statutes are terrible. Because of them, in the scenario I described above, you would be convicted. You could appeal, but the appellate court would just tell you the law is clear. It would use the rules of statutory construction that hurt you while dismissing the ones that help you. If you are convicted, the court may give you a Title 13 enhanced sentence, though it refused to give you a Title 13 necessity defense.

Knowing that, if you ever find yourself in the situation I described above, which I hope you never do, you will realize that you have two choices. You can risk death, or you can risk DUI. You aren’t going to find so much as a scrap of sympathy from any court.

I hope that all of you are as offended by this as I am. I wish I could say that State v. Fell is Arizona’s worst DUI opinion, but it probably isn’t close. It’s just one little sample of Arizona DUI stupidity.

A Couple of Suggestions

Thursday, May 21st, 2009

I regularly hear lawyers make the same stupid mistakes. Here are a couple of suggestions to help them avoid two very common mistakes:

1) Don’t argue ineffective assistance on direct appeal

You can try, but it isn’t going to work. I’ve seen judges appoint new counsel for a direct appeal because they thought appellate counsel might want to argue ineffective assistance. Lawyers have told me they intend to argue ineffective assistance on direct appeal. Please, have a look at State v. Spreitz, 202 Ariz. 1, 3, 39 P.3d 525, 527 (2002). The Supreme Court of Arizona explained:

[I]neffective assistance of counsel claims are to be brought in Rule 32 proceedings. Any such claims improvidently raised in a direct appeal, henceforth, will not be addressed by appellate courts regardless of merit. There will be no preclusive effect under Rule 32 by the mere raising of such issues. The appellate court simply will not address them. This ensures criminal defendants a timely and orderly opportunity to litigate ineffectiveness claims and, we believe, promotes judicial economy by disallowing piecemeal litigation.

You’ll look pretty stupid trying to argue ineffective assistance on direct appeal, and you’ll waste a lot of time doing it. Why does that seem so difficult for lawyers to understand?

2) Don’t assume a federal or out-of-state felony conviction is an historical prior

If you don’t know that, your clients have probably been suffering. “Before a court may use a foreign conviction for sentencing enhancement purposes under § 13-604, the superior court must first conclude that the foreign conviction includes every element that would be required to prove an enumerated Arizona offense.” State v. Smith, 194 P.3d 399, 401, 2008 Ariz. LEXIS 202, 542 Ariz. Adv. Rep. 6 (2008) (internal citations and quotations omitted). “Instead, the trial court must make ‘this determination by comparing the statutory elements of the foreign crime with those in the relevant Arizona statute.’” Id. “[T]here must be strict conformity between the elements of the [foreign] felony and the elements of some Arizona felony.” State v. Clough, 171 Ariz. 217, 219, 829 P.2d 1263, 1265-66 (App. 1992).

I’d guess that almost half of the time, a federal or out-of-state felony conviction isn’t an historical prior. The most common mistake I see involves human smuggling. 8 U.S.C. § 1324(a)(1)(A)(ii)(a) creates criminal penalties for “[a]ny person who . . . knowing or in reckless disregard of the fact that an alien has come to, entered, or remains in the United States in violation of law, transports, or moves or attempts to transport or move such alien within the United States by means of transportation or otherwise, in furtherance of such violation of law.” The analogous statute in Arizona is A.R.S. § 13-2319, which provides, “[i]t is unlawful for a person to intentionally engage in the smuggling of human beings for profit or commercial purpose,” later explaining that “‘[s]muggling of human beings’ means the transportation, procurement of transportation or use of property or real property by a person or an entity that knows or has reason to know that the person or persons transported or to be transported are not United States citizens, permanent resident aliens or persons otherwise lawfully in this state.” A federal conviction could be based on conduct that wouldn’t support an Arizona conviction. You don’t need to look at the indictment. You don’t look any further than the statutes. The federal statute prohibits more conduct, so a conviction under it should not be used to enhance a state sentence.

I could go on for a while with other suggestions, but I don’t have the time. Hopefully this will help someone.

Mandatory Minimums, Maximums

Monday, May 4th, 2009

Arizona’s sentencing statutes contain ranges of permissible prison sentences for different classes of felonies. Defendants with historical prior felony convictions face ranges with longer minimum and maximum sentences.

If a defendant has more than two historical priors, the additional priors may be considered aggravating factors which merit a longer sentence within the statutory range, but there aren’t any special statutory sentencing ranges for people with three, four, or five historical priors. Usually, the most a judge can give someone with two historical priors will be the same as what the judge can give someone with three or more historical priors.

Prosecutors regularly get that wrong. I recently had a prosecutor argue that my client, who had a ton of historical priors and was charged with a class two felony, could get more than the statutory maximum of 35 years. When I asked, the prosecutor couldn’t tell me which law or laws authorized a longer sentence.

The prosecutor agreed that my client couldn’t get less than the mandatory minimum no matter how many mitigating factors the judge found. The law put my client in a specific category, so the preset range for that category applied. My client couldn’t get a sentence under the minimum, but he also couldn’t get a sentence over the maximum. The prosecutor seemed unwilling to make that last jump.

I guess prosecutors are just so used to having the law work only in their favor and against defendants that they forget to apply the same logic to maximum sentences that they apply to minimum sentences.

Some Terrifying New Legislation (Maybe)

Tuesday, February 24th, 2009

One thing Bennett Kalafut mentioned in passing in this post over at Goldwater State caught my attention. Is it really possible that Arizona may soon have a law declaring undocumented aliens to be trespassing? Curious, I had a look at the text of the resolution. Here it is.

If that ever became law, it would have pretty much everything any frothing-at-the-mouth anti-illegal-immigration-type could ever want. It would make it so that aliens in this country in violation of the federal improper entry statute would be committing criminal trespass simply by virtue of being in Arizona. It wouldn’t matter whether they’re on public or private land. The first time, it would be a misdemeanor, but after that, it would be a class 4 felony. That’s the same level of offense as robbery. If the alien has certain drugs or a weapon, it would be a class 2 felony. That’s the same level of offense as kidnapping. Unlike most crimes in Arizona, the alien wouldn’t be eligible for suspension or commutation of sentence or release on any basis until the sentence imposed is served. The statute would also include jail costs and an additional fine. As if that wasn’t enough, part of the proposed legislation would try to give authorities all kinds of unconstitutional powers to enforce it.

I’m not familiar enough with the history of Arizona politics to know if the senate has tried to make that kind of resolution in the past. Hopefully, it will never become a proposition for the people of Arizona to vote into law. My impression is that most Arizonans love making new crimes. The only thing they like better is picking on illegal immigrants. How else do Sheriff Joe and Andrew Thomas manage to keep getting themselves elected? I suspect that law would pass by a landslide. If it does, I shudder to think about the new and creative ways authorities will get around the Constitution to enforce it. Maybe I should start preparing my motions to suppress now.

We're Already Ridiculous

Saturday, February 21st, 2009

For the second time in less than a week, I’ve been inspired to write by a post over at the DUI Blog. I guess that Kentucky, my home state, might pass a law allowing a driver who tests positive for traces of marijuana to be convicted of DUI even if he or she is unimpaired. The DUI Blog puts that in the this-is-getting-ridiculous department. Well, here in Arizona, we’ve been ridiculous for a while.

Arizona’s DUI law says, “[i]t is unlawful for a person to drive or be in actual physical control of a vehicle in this state . . . [w]hile there is any drug defined in section 13-3401 or its metabolite in the person’s body.” Impairment doesn’t matter, as it’s a strict liability crime. If a test can detect a drug or its metabolite in your body, you’ll be charged regardless of the quantity. I’m not saying quantity is a good sign of impairment, but a statutory minimum would at least save some unimpaired drivers from being charged. Currently, in Arizona, even you test positive as a result of legally smoking medical marijuana a couple weeks earlier, that won’t help you one bit. There are also plenty of legal drugs, both prescription and over-the-counter, that might land you in jail if you’re caught driving after taking them.

But don’t worry, the list of drugs in section 13-3401 isn’t that big. Oh wait, nevermind. The list is huge, and who knows how many metabolites each of those drugs has. Aren’t laws supposed to give us some kind of notice about what is and isn’t illegal? It might not be a bad idea to keep a doctor, pharmacist, or maybe chemist on speed dial to make sure you aren’t breaking the law by driving.

To give you an example of how our DUI drug law might convict an innocent person, here’s a little story. A client works a full shift. His managers and co-workers are with him the whole time, and at no point does he use any kind of illegal substance. He gets in his car to drive home. As he leaves the parking lot, he makes a wide right turn, and an officer pulls him over for breaking a traffic law. After approaching, the officer says he smells marijuana and claims the client has a green tongue. The officer asks the client if he recently smoked marijuana, and the client says “yeah, a few weeks ago.” The police report, of course, will merely note “suspect admitted to smoking marijuana.” The client is arrested, and a subsequent blood test eventually comes back positive, though only slightly over the absolute minimum amount the state’s equipment is capable of detecting.

In most instances, that client will be convicted of DUI drugs. Furthermore, his strict-liability DUI drug conviction will result in a one-year driver’s license suspension, not the 90-day suspension a driver actually impaired by alcohol would have gotten. The client will also have to equip his vehicle with an interlock device that does nothing to detect whether he has one of the numerous forbidden drugs or metabolites in his body.

If Kentucky’s legislature has even the tiniest bit of common sense, it won’t go down the ridiculous path we have.