Cited by

¶ 7 (2005), which interpreted a version of Rule 32 from before the Supreme Court adopted a new version of that Rule effective January 1, 2020.

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

¶ 11 (2005) (compliance with Rules governing post- conviction relief petitions is not a mere formality and parties must strictly comply with the Rules to be entitled to relief); ¶ 16 (App. 2013) (concluding the defendant “waived [his] claim on review because he cites no re

Indeed, the State bears both “an ethical and [a] constitutional obligation to disclose clearly exculpatory material that comes to its attention after [] sentencing has occurred.” Canion v. Cole (Canion II), ¶ 8 (2005).

¶12 Discovery in PCR proceedings for a defendant convicted at a trial is governed by Rule 32.6, ¶ 10 (2005).

¶ 11 (2005) (citing cases).

P. 33.2(a)(1); -600 ¶¶ 7, 9 (2005) (finding post-conviction relief rules provide no process for obtaining discovery and impose no disclosure obligations).

¶ 11 (2005) (citing cases).

P. 32.1 (enumerating the grounds for PCR relief); ¶ 12 (2005) (requiring the PCR petitioner to raise “grounds that bring him within the provisions of [Rule 32]”) ().

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

But Arizona’s Supreme Court has previously found that Rule 32 “adopts a liberal policy toward amendment of PCR pleadings.” ¶ 16 (2005).

A. “Good Cause” for Discovery under Rule 32.6(b)(2) ¶18 ¶ 10 (2005), we stated PCR courts have “inherent authority to grant discovery requests in PCR proceedings upon a showing of good cause.” Later, we promulgated Arizona Rule of Criminal Procedure 32.6(b)(2) (effective Jan.

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

¶ 11 (2005); (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

1 Rule 32.5(a) states that a petition “must include a memorandum that contains citations to relevant portions of the record.” “[C]ompliance with Rule 32 is not a mere formality.” ¶ 11 (2005).

¶ 11 (2005) (citation omitted).

The State further argues reconstruction is necessary to complete the record for reference 5 While Rule 15 applies to the trial stage, not to post-conviction relief proceedings, ¶ 9 (2005), we nevertheless find the reciprocal-right-of-discovery rationale applicable.

P. 32.9(c)(4)(B)(iii), (iv) (requiring petitions for review to contain citations to the record and legal authority); ¶ 11 (2005) (petitioner must "strictly comply" with Rule 32 to be entitled to relief).