Cited by

§ 13-751(A)(1); ¶ 11 (2020) (“An order sentencing the defendant to natural life is not subject to commutation or parole, work furlough or work release.”) (cleaned up).

¶ 17 (2020) (Community supervision is not parole because “the meaning of ‘parole’ is not ambiguous or synonymous with other forms of release.”); Vera, 235 Ariz. at 575 ¶ 17 (when statute provided that defendant could not be released on any basis before service of 25 years, defendant’s “only possibilities for rele

§ 41-1604.09(I) (eliminating parole for felony offenses committed after January 1, 1994), Patterson was nonetheless parole-eligible because the superior court’s oral pronouncement of sentence reflects that it “intended that Patterson be eligible for parole after 25 years’ imprisonment.”1 In support of his position, in which the Arizona Supreme Court held that because “a court lacks jurisdiction to correct an illegally lenient sentence absent timely correction or appeal,” “a sentence imposing ‘li

§ 41- 1604.09(I), upon which he relies, in November 2020, and that the COVID-19 pandemic precluded his acting sooner.

Black’s Law Dictionary defines “research” as the “[s]erious study of a subject with the purpose of acquiring more knowledge, discovering new facts, or testing new ideas” and “finding information that one needs to answer a question or solve a problem.” Research, Black’s Law Dictionary (11th ed. 2019); ¶ 14 (2020) (noting that courts generally consult dictionary definitions to ascribe ordinary meaning to a term).

5 STATE V. ANDERSON Opinion of the Court ¶18 ¶ 17 (2020), that “the meaning of ‘parole’ is not ambiguous or synonymous with other forms of release.” Therefore, because Anderson’s sentence provided for the possibility of release after twenty-five years, Arizona law made him eligible for executive clemency or other forms of release after twenty-five years but

15, 2023); ¶ 14 (2020) (observing “[a]bsent statutory definitions, courts apply common meanings and may look to dictionaries”) (citation omitted).

Comm’n, ); –43 ¶ 22 (2020); Tube City Min.

¶ 19 (2020) (–84 (1990)).

§ 41-1604.09(I); ¶ 3 (2020).

The Board held a rescission hearing on October 23, 2019, and took the matter under advisement pending this Court’s

-42, ¶ 15 (2020) (comparing the procedures for obtaining parole with the more demanding burdens of obtaining commutation through executive clemency); see also Graham v. Florida, 560 U.S. 48, 57, 79, 82 (2010) (reasoning that executive clemency is not equivalent to parole because it does not provide a “meaningful”

Thus, the court’s sentencing language is ambiguous because “it is open to multiple reasonable interpretations.” ¶ 9 (2020) ( ¶ 12 (2018)).

See, -43, ¶ 22 (2020) (); Sch.

At ADOC’s request, the Board voted to take the matter under advisement pending our supreme court’s

¶ 19 (2020); see also Dawson, 164 Ariz. at 283–84, 286.

“When the trial court has jurisdiction over the subject matter and parties, the judgment, even if voidable and erroneous, can only be modified on appeal or by proper and timely post-judgment motion.” -43, ¶ 22 (2020) (cleaned up).

After serving 25 years of his sentence, Brookins will likely be entitled to parole consideration, but any such claim now is premature.

¶29 Finally, is inapplicable here.