State v. Reaves
| Citation | 64 Arizona Cases Digest 15,506 P.3d 39 |
| Decision Date | 16 February 2022 |
| Docket Number | 2 CA-CR 2019-0253 |
| Parties | The STATE of Arizona, Appellee, v. James Murray REAVES III, Appellant. |
| Court | Arizona Court of Appeals |
Mark Brnovich, Arizona Attorney General, Linley Wilson, Deputy Solicitor General/Section Chief of Criminal Appeals, By Karen Moody, Assistant Attorney General, Tucson, Counsel for Appellee
James Fullin, Pima County Legal Defender, By Alex Heveri, Assistant Legal Defender, Tucson, Counsel for Appellant
¶1 James Reaves III appeals from his convictions and sentences for first-degree murder, first-degree burglary, and aggravated assault. He argues the trial court erred in denying his challenge to the state's peremptory strike, brought pursuant to Batson v. Kentucky , 476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986), that it made multiple errors in its jury instructions, and that it incorrectly precluded evidence that he suffers from post-traumatic stress disorder. Because we agree the court erred in fulfilling the constitutional obligations set forth by Batson and its progeny, we remand for the court to make findings consistent with this opinion. We otherwise affirm Reaves's convictions and sentences.
¶2 We view the facts in the light most favorable to sustaining the jury's verdicts and resolve all inferences against Reaves. See State v. Felix , 237 Ariz. 280, ¶ 30, 349 P.3d 1117 (App. 2015). Reaves was involved in a romantic relationship with A.T. for a number of years. Beginning in December 2015, he lived with A.T. in a house she shared with her grandmother. In late December 2016, A.T. and Reaves argued, and he was asked to move out of the house. Within two days, Reaves removed his belongings and returned one of the two keys he possessed to the residence. Until the date of the incident, he lived out of his truck.
¶3 One evening in early January 2017, Reaves let himself into the house when A.T. was not home and watched television for a while. He then took a nap in his vehicle, which was parked in the driveway. A.T. and a male friend, D.P., arrived at the house. After D.P. went inside, Reaves had a brief conversation with A.T., telling her that D.P.—whom Reaves did not trust—needed to leave and, at minimum, should not be allowed to stay in A.T.’s bedroom. Reaves later looked into the house's windows and saw A.T. and D.P. together in her bedroom.
¶4 Reaves then drove to a gas station, where he told the attendant he was angry because he had caught his girlfriend cheating and wanted to damage her car. Reaves showed the attendant a metal bar he planned to take with him in case "the guy" tried to "come at him." Reaves continued to text and call A.T. about her relationship with D.P. During one call, Reaves angrily asked A.T. if she and D.P. had just had sex, and she answered in the affirmative. Reaves then screamed at A.T. that she had "better start saying [her] goodbyes" because he was returning to the house and would kill D.P. if he was still there.
¶5 Shortly afterward, Reaves arrived at A.T.’s house. He let himself in, visibly "[v]ery upset," repeated that he was going to kill D.P., and exchanged the metal bar for knives from the kitchen, which he held in both hands. He entered the bedroom, told D.P. to get out, and D.P. refused. D.P. then approached Reaves—smirking according to Reaves—and extended his hand, as if for a handshake. Reaves ducked below D.P.’s hand and stabbed him seventeen times. He also cut A.T.’s arm when she attempted to intervene. D.P. died from his injuries.
¶6 Reaves left the house and returned to the gas station, where he told the attendant he had stabbed a man. He washed his hands and changed out of his bloodied shirt, which he threw in a dumpster before looking up and smiling into a security camera. An acquaintance drove him out of town, where he remained for several days. During the drive, Reaves texted his father, including sending a link to the penalties associated with first-degree murder in Arizona. He also texted two other people, stating he had killed someone. Reaves later testified that he had planned to kill himself, and in preparation he recorded a video on his cell phone in which he admitted to killing D.P. But Reaves ultimately turned himself in to police.
¶7 After a seven-day trial, Reaves was convicted of first-degree murder, first-degree burglary, and aggravated assault, and he was sentenced to natural life in prison, plus 7.5 years. This appeal followed. We have jurisdiction pursuant to A.R.S. §§ 12-120.21(A)(1), 13-4031, and 13-4033(A).
¶8 The Equal Protection Clause of the Fourteenth Amendment to the United States Constitution provides that no state shall "deny to any person within its jurisdiction the equal protection of the laws." In the context of jury trials, this clause ensures that each individual venireperson carries "the right not to be excluded from [a jury] on account of race." Powers v. Ohio , 499 U.S. 400, 409, 111 S.Ct. 1364, 113 L.Ed.2d 411 (1991). It protects a core exercise of democratic participation, because "[o]ther than voting, serving on a jury is the most substantial opportunity that most citizens have to participate in the democratic process." Flowers v. Mississippi , ––– U.S. ––––, 139 S. Ct. 2228, 2238, 204 L.Ed.2d 638 (2019). Therefore, "[e]xclusion of [B]lack citizens from service as jurors constitutes a primary example of the evil the Fourteenth Amendment was designed to cure." Batson , 476 U.S. at 85, 106 S.Ct. 1712. In short, "[t]he Constitution forbids striking even a single prospective juror for a discriminatory purpose." Flowers , 139 S. Ct. at 2244.
¶9 Since Batson , federal law has "vigorously enforced and reinforced the decision, and guarded against any backsliding," Flowers , 139 S. Ct. at 2243, recognizing that "[e]qual justice under law requires a criminal trial free of racial discrimination in the jury selection process," id. at 2242. "[T]rial judges possess the primary responsibility to enforce Batson and prevent racial discrimination from seeping into the jury selection process." Id. at 2243.
¶10 Reaves is Caucasian. His jury pool included two mental health professionals. One, J.F., is Black and holds a PhD in clinical psychology. The other, A.S., is Caucasian, holds a master's degree, and works as a licensed therapist. Each agreed that her professional experiences would not hinder her ability to be fair and impartial. After the state peremptorily struck J.F., Reaves raised a challenge under Batson . The following exchange ensued:
The state did not strike A.S., and she served as a juror.
¶11 We will uphold the denial of a Batson challenge absent clear error. Snyder v. Louisiana , 552 U.S. 472, 477, 128 S.Ct. 1203, 170 L.Ed.2d 175 (2008). We review issues of law de novo. State v. Ross , 250 Ariz. 629, ¶ 16, 483 P.3d 251 (App. 2021). A trial court's Batson ruling generally turns "on evaluation of credibility," either counsel's credibility in articulating a non-racial motive for the strike or the prospective juror's demeanor and asserted ability to serve in a non-biased manner. Batson , 476 U.S. at 98 n.21, 106 S.Ct. 1712 ; see also Purkett v. Elem , 514 U.S. 765, 769, 115 S.Ct. 1769, 131 L.Ed.2d 834 (1995) ; State v. Porter , 251 Ariz. 293, ¶ 11, 491 P.3d 1100 (2021). Because this analysis "is fact intensive," generally "the trial court is in a better position to assess" credibility than is an appellate court. State v. Newell , 212 Ariz. 389, ¶ 54, 132 P.3d 833 (2006). We therefore "afford great deference to trial court findings in this context." Porter , 251 Ariz. 293, ¶ 6, 491 P.3d 1100 ; see also Flowers , 139 S. Ct. at 2244.
¶12 However, "[d]eference does not by definition preclude relief." Miller-El v. Dretke (Miller-El) , 545 U.S. 231, 240, 125 S.Ct. 2317, 162 L.Ed.2d 196 (2005) (alteration in Miller-El ) (applying doubly-deferential standard for reviewing Batson challenges in federal habeas proceedings) (quoting Miller-El v. Cockrell (Miller-El I) , 537 U.S. 322, 340, 123 S.Ct. 1029, 154 L.Ed.2d 931 (2003) ()); see also Snyder , 552 U.S. at 478-79, 128 S.Ct. 1203 (). Rather, to protect the basic principles outlined in Batson and its progeny, we must go beyond a cursory review; we must consider "all of the circumstances that bear upon the issue of racial animosity." Snyder , 552 U.S. at 478, 128 S.Ct. 1203.
¶13 A Batson challenge initiates a three-step process. Johnson v. California , 545 U.S. 162, 168, 125 S.Ct. 2410, 162 L.Ed.2d 129 (2005) ; Newell , 212 Ariz. 389, ¶ 53, 132 P.3d 833. First, the defendant must make a prima facie case that the strike was racially discriminatory. Purkett , 514 U.S. at 767, 115 S.Ct. 1769 ; Newell , 212 Ariz. 389, ¶ 53, 132 P.3d 833. If a prima facie case is made, "the State must provide race-neutral reasons for its peremptory strikes." Flowers , 139 S. Ct. at 2241. The...
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