State of Arizona v. Diondra Sharrelle Howard
CourtArizona Supreme Court
Date FiledAugust 18, 2026
DocketCR-25-0211-PR
StatusPublished
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Full Opinion
IN THE
SUPREME COURT OF THE STATE OF ARIZONA
STATE OF ARIZONA,
Appellee,
v.
DIONDRA SHARRELLE HOWARD,
Appellant.
No. CR-25-0211-PR
Filed August 18, 2026
Appeal from the Superior Court in Maricopa County
The Honorable Jennifer Ryan-Touhill, Judge
The Honorable Chuck Whitehead, Judge
No. CR2015-147837-001
AFFIRMED
Opinion of the Court of Appeals, Division One
260 Ariz. 285 (App. 2025)
VACATED
COUNSEL:
Kristin K. Mayes, Arizona Attorney General, Alice M. Jones, Deputy
Solicitor General/Section Chief of Criminal Appeals, Karen Moody
(argued), Assistant Attorney General, Phoenix, Attorneys for State of
Arizona
Stephen M. Johnson (argued), Law Office of Stephen M Johnson, Phoenix,
Attorney for Diondra Sharrelle Howard
Mikel Steinfeld (argued), Arizona Attorneys for Criminal Justice, Phoenix,
Attorney for Amicus Curiae Arizona Attorneys for Criminal Justice
STATE V. HOWARD
Opinion of the Court
JUSTICE CRUZ authored the Opinion of the Court, in which CHIEF
JUSTICE TIMMER, VICE CHIEF JUSTICE LOPEZ, and JUSTICES BOLICK,
BEENE, KING, and BERCH (Retired) joined.1
JUSTICE CRUZ, Opinion of the Court:
¶1 We granted review to decide whether Arizona Rule of
Criminal Procedure 19.4 required a successor judge, assigned only for
sentencing after the guilt and aggravation phases had concluded, to review
the trial transcripts before imposing sentence. The court of appeals held
that it did. We disagree and hold that Rule 19.4 does not apply. Rule 19.4
governs the replacement of a judge in a proceeding that is interrupted while
it is being heard or tried and directs the successor judge to decide whether
that interrupted proceeding may resume or must be retried. Ariz. R. Crim.
P. 19.4. Here, the guilt and aggravation phases were complete, the court
had discharged the jury, and no sentencing proceeding had begun when
the court reassigned the case; nothing interrupted a proceeding for a
successor judge to resume. Because no interruption occurred during an
ongoing proceeding, Rule 19.4 imposed no obligation on the successor
judge.
¶2 Whether the sentencing judge was sufficiently informed to
impose a sentence is governed not by Rule 19.4 but by Arizona’s sentencing
jurisprudence, including State v. Stotts, 144 Ariz. 72 (1985), and State v. Grier,
146 Ariz. 511 (1985). Under those authorities, Defendant Diondra Howard
has not shown that the sentencing court abused its discretion, conducted an
inadequate investigation, relied on false or misleading information,
prejudiced her, or violated due process. We therefore vacate the court of
appeals’ opinion and affirm the superior court’s sentencing orders.
BACKGROUND
¶3 On October 9, 2015, Howard prepared to celebrate her
birthday with her two sisters. The three stopped at the home of a man they
regarded as an uncle (“Uncle”) to finish getting ready before going out.
1 Justice William G. Montgomery was recused in this matter. Pursuant to
article 6, section 3 of the Arizona Constitution, Justice Rebecca White Berch
(Retired) of the Arizona Supreme Court was designated to sit in this matter.
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STATE V. HOWARD
Opinion of the Court
Howard later discovered that her purse and wallet were missing from her
car, where she had left them. Uncle walked through the neighborhood
looking for those responsible for the theft. He saw two men, asked them
about Howard’s purse, and one of them eventually handed it to him. Uncle
returned the purse to Howard, who became upset upon seeing that the
purse was empty. Uncle described the two men to Howard and told her
where he had seen them. Howard got into a car with her sisters, drove
around, and eventually encountered the two men in a nearby alleyway.
Howard drew a handgun, pointed it at one of the men, and demanded her
property. Howard ultimately shot the man in the head, and he died as a
result. The State charged Howard with one count of second degree murder.
On the final day of a seven-day trial, the jury reached a verdict while
Howard was reportedly still traveling to the courthouse. The jury could
not agree on the second degree murder charge but found Howard guilty of
manslaughter based on sudden quarrel or heat of passion.
¶4 Immediately following the jury’s verdict, and prior to
Howard’s arrival, the trial judge conducted the aggravation phase. The
victim’s mother testified about the effect of her son’s death on the family.
While the jury deliberated on the aggravators, Howard arrived. The jury
returned to the courtroom and announced it had found three aggravating
factors proven. The trial judge set the matter for sentencing and excused
the jury.
¶5 Howard’s mother filed a complaint against the trial judge,
alleging bias based on the judge’s conduct while the jury deliberated on the
aggravating factors. The trial judge recused herself from further
participation in the case without proceeding to sentencing, and the case was
immediately reassigned to another judge.
¶6 Howard moved for a new trial, arguing that the trial judge’s
recusal suggested possible bias or unfairness during trial. The sentencing
judge denied the motion as untimely and reset the matter for sentencing.
¶7 At a status conference, Howard’s counsel (“Counsel”) asked
how the sentencing judge intended to prepare for sentencing, given that he
had not presided over the trial. The judge responded that he planned to
review the relevant sentencing materials but did not believe review of the
trial transcripts was necessary. He added: “If either party thinks that that
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STATE V. HOWARD
Opinion of the Court
is necessary, let me know, and I’ll certainly do that.” Counsel responded,
“[o]kay,” but did not request review of any trial transcript.
¶8 About two months later, before sentencing began, Counsel
expressed concern about the State’s sentencing recommendation, including
that the State had submitted it the day before the sentencing hearing.
Counsel further argued that the State had taken liberties in describing the
evidence and that proceeding before a judge who had neither presided over
the trial nor reviewed the transcripts was “fundamentally unfair.”
¶9 The sentencing judge asked whether Counsel’s concern
related to the recommended sentence. Counsel answered: “It’s not so much
the recommendation itself, Your Honor. It’s the material that the State is
representing as truth, as being how it happened at trial.” But Counsel did
not point to any facts in the sentencing memorandum that were inaccurate
or misleading. The sentencing judge explained that both parties would
present their accounts of the evidence and that the court would
independently determine the appropriate sentence. Though Howard
complained the State had filed its sentencing memorandum on “the eve
before sentencing,” she did not request a continuance or any additional
time to dispute or otherwise address the statements in the memorandum.
¶10 At sentencing, the judge heard arguments from both parties,
including Counsel’s account of the trial evidence. He stated that he had
reviewed the presentence report, the parties’ sentencing memoranda,
Howard’s psychological evaluation and mitigation report, and the letters
submitted on her behalf. The sentencing judge imposed an aggravated
eighteen-year prison term.
¶11 Howard appealed. Neither party invoked Rule 19.4 below or
on appeal; the court of appeals raised it sua sponte and ordered
supplemental briefing, including on the rule’s scope and application. See
State v. Howard, 260 Ariz. 285, 293 ¶ 27 (App. 2025). The court affirmed
Howard’s conviction, rejecting her challenges to the jury instruction and
the alleged judicial bias. Id. at 288 ¶ 1. The court divided over whether the
sentencing judge was required to review the trial transcripts before
imposing sentence. See id. at 297 ¶ 45 (Perkins, J., concurring in part and
dissenting in part).
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STATE V. HOWARD
Opinion of the Court
¶12 The majority vacated the sentence and remanded for
resentencing. Id. at 288 ¶ 1, 296 ¶ 44. It reasoned that Rule 19.4’s plain
language required the sentencing judge to review the record sua sponte to
determine whether continuing the proceeding would be unduly
prejudicial, and that hearing the parties’ sentencing arguments did not
amount to “reviewing the record.” Id. at 293 ¶ 27, 296 ¶ 42. The dissent
would have affirmed Howard’s sentence, reasoning principally that
Rule 19.4 did not apply to a sentencing judge assigned after a completed
proceeding; it acknowledged that reviewing the transcripts may have been
the better practice, but the rule called for sufficient familiarity with the
record to decide whether continuing would cause undue prejudice. Id.
at 297–98 ¶¶ 50–51, 299 ¶ 60 (Perkins, J., concurring in part and dissenting
in part).
¶13 We granted review to address an issue of statewide
importance that is likely to recur. We have jurisdiction under article 6,
section 5(3) of the Arizona Constitution.
DISCUSSION
¶14 This case presents a question about judicial substitution
under Rule 19.4: when the judge presiding over a criminal proceeding
becomes unavailable, and a successor judge is appointed to preside over
the matter, must the successor judge review the transcripts before
proceeding? The parties offer competing answers. The State contends that
Rule 19.4 permits a successor judge to review the transcripts as needed but
does not categorically require it. Howard contends that the rule imposes
an affirmative duty to review the transcripts and independently determine
whether continuing the proceeding would be unduly prejudicial.
¶15 We review the interpretation of the Arizona Rules of Criminal
Procedure de novo. See State v. Whitman, 234 Ariz. 565, 566 ¶ 5 (2014). We
interpret our rules using the same principles that govern statutory
construction. Chronis v. Steinle, 220 Ariz. 559, 560 ¶ 6 (2009); State v. Hansen,
215 Ariz. 287, 289 ¶ 7 (2007). We therefore begin with the text, reading the
rule as a whole, in context, and giving effect to each of its provisions. See
State v. Serrato, 259 Ariz. 493, 496 ¶ 9 (2025); Nicaise v. Sundaram, 245 Ariz.
566, 568 ¶ 11 (2019). If the language is clear, we apply it as written unless
doing so would produce an absurd result or violate the constitution,
4QTKIDZ, LLC v. HNT Holdings, LLC, 253 Ariz. 382, 385 ¶ 5 (2022), and
5
STATE V. HOWARD
Opinion of the Court
when the “plain language is unambiguous in context, it is dispositive,” In
re Drummond, 257 Ariz. 15, 18 ¶ 5 (2024).
I. Rule 19.4 Did Not Apply to a Successor Judge Assigned for
Sentencing After the Guilt and Aggravation Phases of the Trial
Had Concluded
¶16 Rule 19.4 provides:
If the judge who is hearing or trying a criminal proceeding
becomes ill or is otherwise incapacitated, that judge may be
replaced by another judge of the same court. If no other judge
is available, the clerk or bailiff must recess the court and notify
the presiding judge or, if unavailable, the Supreme Court
Chief Justice, who will enter an order continuing the trial until
selection of another judge to resume the proceeding . . . . If the
new judge believes after reviewing the record that continuing
the proceeding would be unduly prejudicial, the judge must
order a new trial or proceeding . . . .
¶17 Rule 19.4 governs the substitution of a judge who becomes
unable to continue presiding over a criminal proceeding. By its terms,
Rule 19.4 operates only when a judge “hearing or trying” a criminal
proceeding is replaced, and a successor judge must decide whether to
“resume the proceeding” or order a new trial. Ariz. R. Crim. P. 19.4. Those
conditions were not present here. When the case was reassigned after the
trial judge’s recusal, the guilt and aggravation phases were complete, the
jury had returned its verdict and found three aggravating circumstances,
and the jury had been discharged; no sentencing proceeding had begun.
No proceeding was interrupted for a successor judge to resume, and
Rule 19.4 did not apply.
¶18 The court of appeals’ majority read Rule 19.4 to require the
sentencing judge to review the trial transcripts before sentencing. Howard,
260 Ariz. at 295–96 ¶¶ 39–43. We disagree, because that reading severs the
rule’s record-review clause from its purpose.
¶19 Rule 19.4 appears in part 6 of the Arizona Rules of Criminal
Procedure, which governs trial proceedings, and the surrounding rules,
likewise, address matters arising during trial. See, e.g., Ariz. R. Crim. P. 21.
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STATE V. HOWARD
Opinion of the Court
Placement of the rule is not dispositive, but it informs the context in which
the rule operates. See Nicaise, 245 Ariz. at 568 ¶ 11. The text points the same
way. Rule 19.4 contemplates a judge “hearing or trying” a criminal
proceeding, directs that another judge may “resume the proceeding,” and
authorizes a new trial if continuation would be unduly prejudicial. These
are the characteristics of a proceeding already underway and interrupted;
they do not apply to successive phases of a criminal case that remain after
substitution.
¶20 The word “proceeding” takes its meaning from context. As
we long ago recognized, the word “has many different meanings,
depending upon the context in which it is used,” and its intended meaning
is “gathered from the context.” Ariz. Corp. Comm’n v. Heralds of Liberty,
17 Ariz. 462, 466 (1916). So understood, “proceeding” can describe an entire
criminal action or a single procedural step or phase within it. See City of
Sedona v. Devol, 196 Ariz. 178, 181 ¶¶ 15–16 (App. 1999) (contrasting
“proceeding” used synonymously with an “action” or “suit” describing
“the entire course of an action” with its use to describe “a mere procedural
step that is part of a larger action” (quoting Proceeding, Black’s Law
Dictionary (6th ed. 1990))). Rule 19.4’s repeated references to hearing,
trying, resuming, and ordering a new trial show that the rule uses
“proceeding” in the latter sense—to mean the particular proceeding
interrupted by the judge’s unavailability, not every subsequent phase of the
case. Read in that light, Rule 19.4 reaches only the interrupted proceeding
itself. Because the trial here was not interrupted but completed, and
sentencing had not begun, the rule did not apply. The rule’s record-review
clause serves only to let a successor judge decide whether an interrupted
proceeding may fairly continue or must be retried—not to prescribe how a
judge must prepare for a later sentencing. Ariz. R. Crim. P. 19.4.
¶21 By the time this case was reassigned to the sentencing judge,
the trial judge had concluded the guilt and aggravation phases of the trial.
The jury had returned its verdict, found three aggravating circumstances,
and had been discharged. Only sentencing remained.
¶22 Howard’s contrary reading would expand Rule 19.4 well
beyond its text. In her view, a successor judge assigned only for sentencing
would have to review the entire trial record to decide whether a new trial
is necessary. But Arizona’s rules already prescribe the procedures for a new
trial. See Ariz. R. Crim. P. 24.1. Nothing in Rule 19.4 suggests that it creates
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STATE V. HOWARD
Opinion of the Court
an alternative mechanism for a successor sentencing judge to reopen
completed trial proceedings merely because a substitution occurred. We
avoid constructions that produce such incongruous results. See State ex rel.
Montgomery v. Harris, 237 Ariz. 98, 102 ¶ 14 (2014).
¶23 We do not suggest that Rule 19.4 is categorically inapplicable
to sentencing. Had a judge’s unavailability interrupted an ongoing
sentencing proceeding, the successor judge would have to determine
whether that proceeding could fairly continue. But no sentencing
proceeding had begun when this case was reassigned. Nor do we decide
the outer limits of judicial incapacity under the rule—the triggering event
here being the trial judge’s recusal rather than illness or incapacity—which
is an issue the parties did not brief. It is enough that Rule 19.4 does not
reach a successor judge assigned solely to conduct a sentencing that had not
begun.
¶24 We therefore hold that Rule 19.4 did not apply to the
sentencing, because no proceeding was interrupted while being heard or
tried, and no sentencing proceeding had begun. Whether the sentencing
judge possessed sufficient information to impose a sentence is governed not
by Rule 19.4 but by Arizona’s sentencing statutes, rules, and decisions
concerning abuse of discretion and due process.2
2 Nothing in our analysis should be understood to suggest that a successor
judge has no ethical obligation to be adequately prepared. The Arizona
Code of Judicial Conduct requires a judge to perform judicial and
administrative duties “competently, diligently, and promptly,” Ariz. Code
of Jud. Conduct R. 2.5(A), and the comment to that rule treats competence
as encompassing the preparation reasonably necessary to discharge the
judge’s responsibilities. Howard has not contended that the sentencing
judge violated any such obligation. In any event, the Code “is not designed
or intended as a basis for civil or criminal liability,” nor as a basis “for
litigants to seek collateral remedies against each other or to obtain tactical
advantages in proceedings before a court.” Id. The adequacy of the
sentencing court’s preparation is, therefore, governed by the sentencing
standards discussed below, not by the Code.
8
STATE V. HOWARD
Opinion of the Court
II. Arizona Sentencing Law Governs the Adequacy of the Sentencing
Judge’s Investigation and Howard’s Due Process Claim
¶25 Because Rule 19.4 did not govern the sentencing judge’s
preparation for sentencing, we turn to the standards that do. Howard
contends that being sentenced by a judge who had not reviewed the trial
transcripts deprived her of due process and produced an inadequately
informed sentence. The court of appeals resolved the appeal solely under
Rule 19.4 and did not reach whether the sentencing court conducted an
adequate investigation or denied Howard due process. Those issues were
raised in the superior court and briefed in the court of appeals, and, after
oral argument in this court, we ordered supplemental briefing directing the
parties to address them. When a party raises an issue in the court of appeals
that the court does not decide, Rule 31.21(l)(2) permits this Court to decide
the issue, remand the issue to the court of appeals, or dispose of the issue
as appropriate.
¶26 Although both parties suggested a remand would be
appropriate to resolve the outstanding issues here, Howard’s remaining
claims present questions of law resolvable on a fully developed record and
require only the application of settled sentencing law to undisputed facts.
Judicial economy, therefore, favors resolving them now, and we do so
rather than remanding the case, because Howard has fully briefed these
issues here so that deciding them does not deprive her of the appellate
consideration to which she is entitled.
¶27 Arizona’s sentencing statutes and rules identify the
information a sentencing court may receive and must consider.
Section 13-701(C) of the Arizona Revised Statutes provides that mitigating
circumstances may be established through evidence or information
presented at trial or at sentencing. Section 13-701(G) requires the court to
state on the record the factual findings supporting an aggravated or
mitigated sentence. Article 2, section 2.1(A)(4) of the Arizona Constitution
affords crime victims the right to be heard at sentencing, and Rule 26.7
authorizes the parties to present evidence and information relevant to
sentencing. Ariz. R. Crim. P. 26.7(b)(2). Together these authorities establish
that sentencing is an individualized determination informed by the
information properly presented to the court.
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STATE V. HOWARD
Opinion of the Court
¶28 Arizona law also fixes the standard by which we review the
adequacy of a sentencing court’s investigation. See Stotts, 144 Ariz.
at 87–88. In Stotts, we explained that a sentence within the statutory range
will not be disturbed absent an abuse of discretion, which occurs when the
decision is arbitrary or capricious or when the court fails “to conduct an
adequate investigation into the facts relevant to sentencing.” Id. at 87. The
question is, therefore, not whether the judge reviewed every available
source, but whether the court had sufficient reliable information to exercise
its sentencing discretion intelligently.
¶29 In Grier, 146 Ariz. at 515, we recognized that a defendant has
a due process right to a fair sentencing procedure, which includes the right
to be sentenced on the basis of accurate information—a principle drawn
from United States v. Tucker, 404 U.S. 443, 447 (1972). A sentencing court
accordingly abuses its discretion when it fails to investigate facts necessary
to the intelligent exercise of its sentencing authority. Grier, 146 Ariz. at 517.
But a defendant does not obtain relief merely by disputing the court’s
characterization of the evidence. The defendant must show both that the
information before the court was materially false or misleading and that the
court relied on that information in imposing a sentence. Id. at 515.
¶30 These principles frame Howard’s claim. The dispositive
issues are whether the sentencing court conducted an adequate
investigation into the facts relevant to sentencing, whether it relied on
materially false or misleading information, and whether any deficiency
deprived Howard of a fundamentally fair proceeding. We address each
issue in turn.
III. Howard Has Not Established an Abuse of Discretion or a Due
Process Violation
¶31 Howard has not satisfied the standards of Stotts and Grier.
She identifies no materially false or misleading information presented to
the sentencing court and no finding the sentencing judge made using or
applying objectively inaccurate information. Instead, she disputes the
State’s characterization of the evidence and the sentencing judge’s
assessment of her conduct. Neither dispute establishes reliance on
materially false or misleading information.
10
STATE V. HOWARD
Opinion of the Court
¶32 The State characterized Howard’s conduct as a deliberate,
rage-driven decision to arm herself and take the law into her own
hands—hunting down the victim over a stolen purse, confronting him at
gunpoint and shooting him, then abandoning him and fleeing the scene
rather than calling for help. The State argued that these actions reflected a
sustained lack of remorse that, together with the statutory and
non-statutory aggravators, warranted the maximum sentence. The
sentencing judge, in turn, characterized the offense as “a senseless act of
violence that has affected so many people” and observed that “[w]e as a
society don’t allow vigilantism.” Howard challenges the “vigilantism”
characterization in particular. But in context, the sentencing judge used that
term to describe her decision to pursue a confrontation rather than leave
the matter to law enforcement. Whether described as vigilantism, taking
the law into one’s own hands, or seeking out a confrontation, the factual
premise for the characterization finds support in the record. Disagreements
with the State’s or the sentencing judge’s characterization of the evidence,
therefore, do not show that the sentencing judge relied on materially false
or misleading information. See Grier, 146 Ariz. at 515; cf. State v. Herrera,
176 Ariz. 9, 19 (1993).
¶33 Nor has Howard shown that the sentencing judge failed to
conduct an adequate investigation. Before sentencing, the judge reviewed
the presentence report, the parties’ sentencing memoranda, Howard’s
psychological evaluation and mitigation report, and the letters submitted
on her behalf. He heard arguments from both parties, including Counsel’s
account of the trial evidence. Those materials informed him about the
offense, Howard’s background and circumstances, the aggravating and
mitigating factors, and the impact of the offense on the victim’s family.
Howard identifies no category of relevant sentencing information the
sentencing judge refused or failed to consider. On this record, the
investigation was adequate under Stotts. See 144 Ariz. at 87.
¶34 Howard also failed to identify any specific portion of the trial
record that required review before sentencing. At the status conference,
Counsel asked in general terms whether the sentencing judge would review
the transcripts. The judge answered that he did not believe review was
necessary but expressly invited the parties to identify materials warranting
review. Howard did not request review of any particular transcript,
witness, exhibit, or factual dispute. When Counsel later objected at
sentencing, she again asserted only that the State had taken liberties with
11
STATE V. HOWARD
Opinion of the Court
the evidence, without identifying any challenged statements or directing
the court to the portions of the record showing their inaccuracy. And
though the State submitted its sentencing memorandum on the eve of the
sentencing hearing, Howard did not request additional time to prepare or
investigate any statement contained in that memorandum. Howard’s
generalized objections did not give the sentencing judge a meaningful
opportunity to investigate or correct any alleged error. See State v. Rutledge,
205 Ariz. 7, 13 ¶ 30 (2003) (“The purpose of an objection is to permit the trial
court to rectify possible error, and to enable the opposition to obviate the
objection if possible.” (quoting State v. Hoffman, 78 Ariz. 319, 325 (1955))).
¶35 Howard has, likewise, not shown that reviewing the
transcripts would have affected the sentence. She identifies no factual
misunderstanding that review would have corrected, no aggravating
circumstance the sentencing judge improperly considered, and no
mitigating evidence he overlooked. Her claim, thus, rests on the premise
that transcript review was required as a matter of procedure, not on any
showing that its absence affected the sentence. Stotts and Grier require
more: a showing that the sentencing process was inadequately informed or
that the sentencing judge relied on materially false information. Stotts,
144 Ariz. at 87; Grier, 146 Ariz. at 515. Howard has shown neither.
¶36 Finally, Howard has not established prejudice. She has never
identified what the sentencing judge would have learned by reviewing the
trial transcripts or how that information would have altered the judge’s
exercise of discretion. See State v. Alston, 261 Ariz. 82, 90 ¶ 24 (App. 2025)
(explaining that to justify resentencing, a defendant “must demonstrate that
absent the error the court could have reasonably imposed a lighter
sentence”). At oral argument here, defense counsel conceded that no
appellate issue would remain if the sentencing judge reviewed the
transcripts, reached the same conclusions, and imposed the same sentence.
That concession underscores the absence of demonstrated prejudice from
the procedure that was followed here.
¶37 We do not suggest that the sentencing judge could not or
should not have undertaken additional review. Reviewing more of the
record or continuing the sentencing hearing may well have been prudent.
See Howard, 260 Ariz. at 299 ¶ 60 (Perkins, J., concurring in part and
dissenting in part). But due process does not require the best possible
procedure; it requires a fundamentally fair one. See Rivera v. Illinois,
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STATE V. HOWARD
Opinion of the Court
556 U.S. 148, 158 (2009). Howard has not pointed to any evidence that the
sentencing judge conducted an inadequate investigation, relied on
materially false or misleading information, or denied Howard a fair
opportunity to present mitigation and to contest the State’s arguments. She
has, therefore, failed to establish either an abuse of discretion under Stotts,
144 Ariz. at 87, or a due process violation under Grier, 146 Ariz. at 515.
CONCLUSION
¶38 We hold that Rule 19.4 did not apply to the judge assigned to
conduct Howard’s sentencing, because no proceeding was interrupted
while being heard or tried and no sentencing proceeding had begun.
Rule 19.4’s record-review requirement serves only to determine whether an
interrupted proceeding may continue without undue prejudice and does
not prescribe the preparation a successor judge must undertake before a
sentencing that is held after the guilt and aggravation phases have
concluded. Whether the court possessed sufficient information to impose
sentence is governed by Arizona’s sentencing statutes, rules, and decisions,
including Stotts and Grier.
¶39 Because Howard has not shown that the sentencing court
conducted an inadequate investigation, relied on materially false or
misleading information, abused its discretion, or violated due process, we
vacate the opinion of the court of appeals and affirm the superior court’s
sentencing order.
13