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State v. Gutierrez
Citations: 307 P.2d 914; 82 Ariz. 21; 1957 Ariz. LEXIS 185Docket: 6339
Court: Arizona Supreme Court; February 26, 1957; Arizona; State Supreme Court
In **Steven Reyes Gutierrez v. State of Arizona**, the petitioner, Gutierrez, was convicted of unlawfully dispensing narcotics, specifically heroin, and sentenced to nine to twelve years in prison. He appealed the conviction, which was affirmed by the Supreme Court of Arizona. Subsequently, Gutierrez sought a writ of habeas corpus, claiming that the statute under which he was convicted violated the equal protection and due process clauses of the 14th Amendment. He argued that the statute imposed different degrees of punishment, thus denying equal protection, and that it lacked clarity in defining the crime, violating due process. Furthermore, he contended that the legislature could not delegate its law-making powers to the judiciary. The court found no merit in the equal protection claim, asserting that while setting punishments is a legislative function, the imposition of sentences is a judicial responsibility. The court noted that the uniformity of the statute's punitive clause has not been constitutionally challenged in other states. Ultimately, the court upheld the lower court’s decision to quash the habeas corpus writ. Section 13-1643, A.R.S. 1956, enacted as Chap. 46, Laws 1912, mandates indeterminate sentences for all felonies except first-degree murder, granting courts the authority to impose varying sentences based on offender backgrounds. The statute's validity is upheld as it aligns with equal protection principles, similar to precedents in other jurisdictions. Under this act, a court can sentence a first-time offender to one to five years and a recidivist to five to ten years without violating equal protection rights. Additionally, the court may suspend the sentence for first offenders, which would raise more significant equal protection concerns than imposing a lighter sentence. The appellant's claim that reducing a felony to a misdemeanor is a legislative function is incorrect; establishing punishment is a judicial function in Arizona, as the legislature has defined the offense's character. California's similar statutes affirm that an offense maintains its felony status until judgment, supporting the constitutionality and due process of the statute. The court affirms the order quashing the writ, with concurrence from multiple justices.