Arizona Supreme Court: State of Arizona v. Christopher Michael Montoya
Case No. CR-22-0106-AP Filed August 15, 2024
ISSUES: NOTE: This is an automatic appeal because it is a capital case.
- Whether the prosecutor committed errors that denied Montoya due process, a fair trial, and freedom from arbitrary punishment.
- Whether the prosecutor improperly argued an unproven aggravator during closing arguments.
- Whether the prosecutor improperly appealed to jurors’ emotions.
- Whether the prosecutor improperly used victim impact statements to argue for the death penalty.
- Whether the prosecutor made improper comparative life arguments.
- Whether the prosecutor improperly used mitigation evidence as non-statutory aggravation.
- Whether the prosecutor misstated the law on mitigation.
- Whether the prosecutor engaged in improper vouching.
- Whether the prosecutor improperly solicited character evidence.
- Whether the prosecutor improperly commented on Montoya’s decision not to allocute.
- The prosecution violated his sixth and eighth amendment rights.
DECISION:
The Arizona Supreme Court rejected all of Montoya’s claims of prosecutorial error, finding that the prosecutor’s statements and actions were either proper or did not rise to the level of fundamental error requiring reversal.
Synopsis:
Montoya was convicted of first-degree murder and other charges related to the brutal killing of A.R. He was sentenced to death for the murder. On automatic appeal, Montoya argued that the prosecutor committed various errors that denied him a fair trial. The court applied established principles of prosecutorial misconduct review, often using the fundamental error standard due to Montoya’s failure to object at trial.
Outcome:
The Arizona Supreme Court affirmed Montoya’s convictions and sentences, including the death sentence for first-degree murder.