State v. Bigger
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The Supreme Court vacated the opinion of the court of appeals affirming the decision of the trial court summarily denying relief as to Petitioner's petition for post-conviction relief and affirmed the trial court's ruling dismissing Petitioner's PCR petition, holding that Petitioner's claims did not warrant relief.
Specifically, the Supreme Court held (1) a defendant need not present a standard of care expert affidavit to support his ineffective assistance of counsel claim, and the trial court did not abuse its discretion in ruling that Petitioner failed to present colorable IAC claims; (2) Perry v. New Hampshire, 565 U.S. 228 (2012), did not cause a significant change in Arizona law; and (3) Ariz. Rev. Stat. 13-4234(G) unconstitutionally conflicts with the procedure established by the Supreme Court in Ariz. R. Crim. P. 32.4.
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