State of Arizona, Appellee v. James Edward Davolt, Ii, Appellant

Summary

The Arizona Supreme Court affirmed James Edward Davolt II's convictions for two first degree murders, burglary, theft, arson, and theft of means of transportation, but remanded his death sentences because Arizona's automatic filing statute subjected him—a sixteen-year-old—to capital prosecution without any individualized assessment of his maturity and moral responsibility, which the court held the Eighth Amendment requires. The court also held that the warrantless search of his motel room rested on consent severely tainted by multiple constitutional violations and that the inevitable discovery doctrine could not cure them, although admission of that evidence was harmless beyond a reasonable doubt. Finally, it vacated the non-capital sentences because the trial court failed to consider Davolt's age as a statutory mitigating factor.