State of Arizona v. Diondra Sharrelle Howard

Summary

The court held that Arizona Rule of Criminal Procedure 19.4 did not require a successor judge assigned solely to sentencing to review the trial transcripts because no proceeding was interrupted and sentencing had not begun when the reassignment occurred. The court instead applied ordinary sentencing-law standards and concluded that Howard failed to show an inadequate investigation, reliance on materially false or misleading information, prejudice, abuse of discretion, or a due process violation. The court vacated the court of appeals’ opinion and affirmed the superior court’s sentencing order.