Chronis v. Steinle

OPINION

BALES, Justice.

¶ 1 We hold that Arizona Rule of Criminal Procedure 13.5(e) permits a defendant in a capital murder case to request a determination of probable cause as to alleged aggravating circumstances.

I

¶ 2 Ryan Chronis was arrested after police found the body of his girlfriend, Brianna Wood, in the car he was driving. A grand jury indicted Chronis for first-degree murder. The State subsequently filed an Allegation of Death Penalty and Notice of Aggravating Factors, alleging that Chronis had killed Wood in an “especially heinous, cruel or depraved manner.” See Ariz.Rev.Stat.…