Cruz v. Arizona

The Supreme Court vacated the Arizona Supreme Court's decision and sent the case back. It said Arizona's conclusion that Lynch was not a significant change in the law was a novel and unforeseeable use of a procedural rule, so it could not block review of Cruz's federal claim.

The Court ruled 5-4. Justice Sonia Sotomayor wrote the majority opinion, joined by Chief Justice John Roberts and Justices Elena Kagan, Brett Kavanaugh, and Ketanji Brown Jackson. Justice Amy Coney Barrett dissented, joined by Justices Clarence Thomas, Samuel Alito, and Neil Gorsuch.

Majority

Sotomayor

Roberts

Kagan

Kavanaugh

Jackson

Dissent

Barrett

Thomas

Alito

Gorsuch

“This was an "exceptional case" involving a "novel and unforeseeable interpretation" of a state procedural rule.”

The decision prevents Cruz's federal claim from being blocked by that Arizona procedural ruling. It also means other people seeking review of federal constitutional claims may challenge state procedural barriers that are applied in unforeseeable ways.

The Arizona Supreme Court must take up the case again in light of the Supreme Court's decision. Cruz's claim remains subject to further proceedings; the ruling does not itself resolve the claim's ultimate merits.

The Court ruled that Arizona's procedural ruling was too novel and unforeseeable to block review of Cruz's federal claim.

Cruz can continue seeking review of his federal claim. Others may cite the decision when a state procedural rule is applied unexpectedly.

The case returns to the Arizona Supreme Court for further proceedings consistent with the Supreme Court's decision.