Cited by

Rule 32.1(g) provides relief only when there has been a “significant change in the law that, if applicable to the defendant’s case, would probably overturn the defendant’s judgment or sentence.” “[A] change in the law requires some transformative event, a ‘clear break’ from the past.” ¶ 15 (2009) (citation omitted).

¶ 12 (2009) (“By requiring that all post-conviction claims be raised promptly,” the PCR rules “not only serve[] important principles of finality, but also allow[] any relief to be issued at a time when the interests of justice .

P. 32.2(a); ¶ 12 (2009) (PCR is precluded when based on a ground that was or could have been decided on appeal).

Wade’s “enhanced sentence [is] retroactively illegal.” Id.; ¶ 14 (2009) (“In those rare cases when a “new rule” of law is announced, Rule 32.1(g) provides a potential avenue for relief.”).

“To prevent endless or nearly endless reviews of the same case in the same trial court, Rule 32.2(a) precludes collateral relief on a ground that either was or could have been raised on direct appeal or in a previous PCR proceeding.” ¶ 12 (2009).

On the contrary, Rule 32.2(a) “precludes collateral review” of a defendant’s conviction or sentence “on a ground that either was or could have been raised on direct appeal or in a previous PCR proceeding.” ¶ 12 (2009) (citation omitted).

P. 32.2(a); ¶ 12 (2009) (PCR is precluded when based on a ground that was or could have been decided on appeal.).

–19 ¶¶ 15–17 (2009) (noting that, for a Rule 32 PCR petition to be granted on the basis of “a significant change in the law,” the new law must: (1) clearly break from past law and (2) have retroactive application); ¶ 5 (2003) (noting that for purposes of a Rule 32 PCR p

¶16 A significant change in the law “requires some transformative event, a clear break from the past.” ¶ 15 (2009) (citation omitted).

Sixty days after filing the notice or appointment of counsel, “[t]he defendant must then file a PCR petition including evidentiary, record, and legal support for his claims.” ¶ 16 n.6 (2009); Ariz. R. Crim.

As a result, this court analyzes Williams’ claim under Rule 33.1(g).2 ¶6 Rule 33 “does not define ‘a significant change in the law.’ But plainly a ‘change in the law’ requires some transformative event, a ‘clear break from the past.’” ¶ 15 (2009) (); ¶ 28 (2021); ¶ 13 (2021); cf. Slemmer, 170 Ariz. at 182 (“a significant change in the law” is “a ‘sharp break’ with the past”).

See Pierson, 107 Ariz. at 387; ¶ 12 (2009) (post-conviction relief precluded when the ground alleged either was or could have been raised on direct appeal or in a previous proceeding).

P. 32, 33, provide a “single comprehensive remedy,” ¶¶ 11– 12 (2009); see also Ariz. R. Crim.

¶28 A significant change in the law pursuant to Arizona Rule of Criminal Procedure 32.1(g) “requires some transformative event, a clear break from the past.” ¶ 15 (2009) () (internal quotation marks omitted).

¶13 A significant change in the law pursuant to Rule 32.1(g) “requires some transformative event, a clear break from the past.” ¶ 15 (2009) (quotation marks omitted) ().

¶ 15 (2009) (quotation omitted).

P. 32.1(c), 32.2(b); –20 ¶¶ 3–23 (2009).

¶¶ 1-3 ; see also State v. Shrum , , ¶ 11, ("Rule 32 ...

See, -55, ¶¶ 9-10 (2013); ¶¶ 11-12 (2009) (stating that Rule 32 consolidated most avenues for post-conviction relief into “a single comprehensive remedy,” and that it generally precludes collateral relief on a ground that was or could have been raised on direct appeal or in a previous post-conviction relief petition).

¶ 22 (App. 2016) (a personal representative acts on behalf of an estate, which is “a collection of the decedent’s assets and liabilities”); ¶ 11 (2009) (with few exceptions, Rule 32 was meant to consolidate most avenues of post-conviction relief “into a single comprehensive remedy”); see also Heck v. Humphrey, 512 U.S. 477, 484-86 (1994) (reaffirming the well- established principle that civil suits “are not appropriate vehicles for challenging the v

A significant change in the law “requires some transformative event, a clear break from the past.” ¶ 15 (2009) (citation omitted).