Page:Cruz v. Arizona (2023).pdf/22

Rh 32.1(g). Context, however, shows there is more to the story: Shrum illustrated its point with the example of Ring v. Arizona, 536 U. S. 584 (2002), which was a significant change because it overruled our contrary decision in Walton v. Arizona, 497 U. S. 639 (1990). 220 Ariz., at 118–119, 203 P. 3d, at 1178–1179 (citing State v. Towery, 204 Ariz. 386, 390, 64 P. 3d 828, 832 (2003)). Unlike Lynch, Ring changed the governing legal doctrine, not a mistaken application of that doctrine. So Shrum’s reasoning is not inconsistent with the result below.

The Court also asserts that Arizona courts typically analyze how an intervening decision affects the law in Arizona, so by that logic, decisions like Lynch that change the law’s on-the-ground application in Arizona constitute grounds for relief under Rule 32.1(g). I do not read the Arizona Supreme Court’s “past unambiguous holdings” to say as much. Patterson, 357 U. S., at 456. The closest example the Court offers is State v. Valencia, 241 Ariz. 206, 386 P. 3d 392 (2016), in which the Arizona Supreme Court considered whether Miller v. Alabama, 567 U. S. 460 (2012), constituted a significant change in law. 241 Ariz., at 208, 386 P. 3d, at 394. The court observed that pre-Miller, “Arizona law” allowed trial courts to impose life sentences on juveniles “without distinguishing crimes that reflected ‘irreparable corruption’ rather than the ‘transient immaturity of youth.’ ” Valencia, 241 Ariz., at 209, 386 P. 3d, at 395. Miller, in holding that trial courts must weigh such considerations before imposing a life sentence on juveniles, changed Eighth Amendment doctrine and therefore changed the law in Arizona. 241 Ariz., at 209, 386 P. 3d, at 395; see also Montgomery v. Louisiana, 577 U. S. 190, 208, 212 (2016). Lynch, by contrast, did not change the content of federal law and therefore did not change the law in Arizona.

If the Arizona Supreme Court’s distinction between a change in law and a change in the application of law seems