Allen v. Honorable Teresa A. Sanders
Annotate this CaseSammantha Allen and John Allen, a married couple, were indicted by a grand jury for first degree felony murder. The indictment concurrently charged the Allens with multiple counts of child abuse. The State filed a notice of intent to seek the death penalty, alleging the child abuse offenses as “serious offense” aggravating circumstances under Ariz. Rev. Stat. 13-751(F)(2). At the Allens’ request, the trial court conducted a hearing under the procedures outlined in Chronis v. Steinle and determined that probable cause existed for the serious offense aggravators because the grand jury found that probable cause existed for the alleged aggravating circumstances. The court of appeals reversed, concluding that Sanchez v. Ainley required the trial court to independently determine whether probable cause existed for the serious offense aggravators. The Supreme Court vacated the court of appeals’ opinion and affirmed the judgment of the trial court, holding that the trial court must independently determine if a concurrently charged offense qualifies as a serious offense, but the court should accept the grand jury’s determination that probable cause exists for the concurrently charged offense.
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