Cruz v. Arizona (Post conviction)

Cruz v. Arizona is a case heard by the US Supreme Court that questioned whether the Arizona Supreme Court's ruling was an adequate ground to preclude review of a federal question. The petitioner, John Montenegro Cruz, was found guilty of capital murder and sentenced to death, and argued that under Simmons v. South Carolina, he should have been allowed to inform the jury that a life sentence in Arizona would be without parole. Cruz sought to raise the Simmons issue again in a state post-conviction petition under Arizona Rule of Criminal Procedure 32.1(g). The Arizona Supreme Court denied relief after concluding that Lynch was not "a significant change in the law". The US Supreme Court held that the Arizona Supreme Court's holding that Lynch was not a significant change in the law is an exceptional case where a state-court judgment rests on such a novel and unforeseeable interpretation of a state-court procedural rule that the decision is not adequate to foreclose review of the federal claim.