State of Arizona v. David Nikolas Delich

CourtCourt of Appeals of Arizona
DecidedMay 14, 2025
Docket2 CA-CR 2024-0224-PR
StatusPublished

This text of State of Arizona v. David Nikolas Delich (State of Arizona v. David Nikolas Delich) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Arizona v. David Nikolas Delich, (Ark. Ct. App. 2025).

Opinion

IN THE ARIZONA COURT OF APPEALS DIVISION TWO

THE STATE OF ARIZONA, Respondent,

v.

DAVID NICKOLAS DELICH, Petitioner.

No. 2 CA-CR 2024-0224-PR Filed May 14, 2025

Petition for Review from the Superior Court in Pima County No. CR20082239001 The Honorable Danielle J.K. Constant, Judge

REVIEW GRANTED; RELIEF DENIED

COUNSEL

Laura Conover, Pima County Attorney By J. William Brammer, Jr. and James W. Rappaport, Deputy County Attorneys, Tucson Counsel for Respondent

Megan Page, Pima County Public Defender By David J. Euchner, Assistant Public Defender, Tucson Counsel for Petitioner STATE v. DELICH Opinion of the Court

OPINION

Presiding Judge Eckerstrom authored the opinion of the Court, in which Judge Vásquez and Judge Sklar concurred.

E C K E R S T R O M, Presiding Judge:

¶1 David Delich seeks review of the superior court’s order summarily dismissing his petition for post-conviction relief filed pursuant to Rule 33, Ariz. R. Crim. P. We will not disturb that decision absent an abuse of discretion, see State v. Hagerty, 255 Ariz. 112, ¶ 1 (App. 2023), which Delich has not demonstrated here.

¶2 In 2012, Delich pled guilty except insane (GEI) to seven counts of aggravated assault with a deadly weapon and two counts of discharging a firearm at a residential structure. See A.R.S. § 13-502(A) (“A person may be found guilty except insane if at the time of the commission of the criminal act the person was afflicted with a mental disease or defect of such severity that the person did not know the criminal act was wrong.”). He also pled guilty to first-degree murder and an additional count of aggravated assault with a deadly weapon. For the GEI counts, the superior court placed Delich under the supervision of the Psychiatric Security Review Board for an aggregate term of 91.5 years. For Delich’s remaining convictions, the court imposed concurrent prison terms, including a life term for first-degree murder without release eligibility for twenty-five years.

¶3 In 2024, Delich sought post-conviction relief for the first time. He argued, under Rule 33.1(h), that his non-GEI convictions should be “modified to GEI adjudications” because no reasonable jury could have found him guilty beyond a reasonable doubt and instead would have found him GEI. He additionally asserted that the twelve-year delay in seeking relief did not bar his claim, because counsel had only recently determined that his “novel[]” claim was viable under Rule 33.1(h).

¶4 The superior court summarily dismissed Delich’s petition. It first determined the claim was untimely because Delich and his counsel understood at the time of the 2012 change-of-plea hearing “the possible legal issues with Delich accepting a plea to both guilty and guilty-except-insane from the same indictment.” The court concluded that

2 STATE v. DELICH Opinion of the Court

the twelve-year delay was thus unreasonable. The court also rejected Delich’s claim on the merits, noting the state was required to prove his guilt beyond a reasonable doubt whether the ultimate verdict was guilty or GEI and that either verdict imposed “criminal culpability.” Thus, the court concluded, the claim “does not fall under the auspices of Rule 33.1(h).” This petition for review followed.

¶5 We first address Delich’s argument on review that he timely sought relief under Rule 33.1(h). Rule 33.4(b)(3)(B) requires that a claim under Rule 33.1(h) must be filed “within a reasonable time after discovering the basis for the claim.” In Delich’s view, any reasonable jury would have found him GEI instead of guilty if his case had proceeded to trial. Therefore, notwithstanding that he pled guilty—rather than GEI—to the underlying offenses, he contends that he qualifies for relief. See Ariz. R. Crim. P. 33.1(h) (providing potential remedy when petitioner presents facts demonstrating “no reasonable fact-finder would find the defendant guilty of the offense beyond a reasonable doubt” had those facts been presented). He relies primarily on State v. Reed, 252 Ariz. 236 (App. 2021), and State v. Solano, 257 Ariz. 10 (App. 2024), in asserting that he raised this claim within a reasonable time. Neither case aids his argument.

¶6 In Reed, the defendant pled guilty to attempted reckless child abuse—an offense that does not exist under Arizona law. 252 Ariz. 236, ¶¶ 8-9. But he did not contest his conviction on that basis until years later, in his second post-conviction proceeding. Id. ¶ 4. We nonetheless determined Reed had brought his claims under Rule 33.1(c) and (h) within a reasonable time under Rule 33.4(b)(3)(B). Id. ¶ 15. We noted that when evaluating whether a defendant’s delay in bringing a claim was reasonable, courts should consider several factors, including “the consequences of a failure to address the merits of the claim and the prejudice to the State or victim.” Id. ¶ 14. Because his conviction and sentence were illegal and the state asserted no prejudice, we concluded the delay was reasonable under the circumstances. Id. ¶ 14. We held that, “when a defendant pleads guilty to an offense not cognizable under Arizona law, an illegal-sentence claim under Rule 33.1(c) or actual-innocence claim under Rule 33.1(h) is not time-barred if there is no evidence presented beyond the mere passage of time to suggest unreasonable delay.” Id. ¶ 15.

¶7 But, although Delich characterizes his claim as falling within Rule 33.1(h), it is not a claim of actual innocence. Delich has not identified any defect in the factual basis for his plea nor otherwise suggested his conviction is improper. And the prejudice to the state is apparent—it

3 STATE v. DELICH Opinion of the Court

would lose the benefit of a bargained-for plea agreement based, in part, on Delich’s voluntary decision to forgo a GEI defense to avoid facing the death penalty. In any event, Reed does not address the question presented here— the meaning of “the basis for the claim” under Rule 33.4(b)(3)(B).

¶8 In Solano, the defendant asserted a claim under Rule 32.1(f) that his failure to timely appeal was not his fault. 257 Ariz. 10, ¶ 3. The trial court rejected the claim, concluding the three-year delay in bringing the claim was unreasonable. It so found notwithstanding Solano’s explanation that he was unaware the appeal had not been filed because the COVID-19 pandemic had prevented him from communicating with those from whom he eventually learned that he should have heard the status of his appeal by that time. Id. ¶¶ 5, 12. We granted relief on review, noting that Rule 32.4(a)(3)(B) did not require Solano to “discover his claim within a reasonable time” but instead to raise it within a reasonable time of discovery. Id. ¶¶ 11, 14.

¶9 But, like our decision in Reed, our decision in Solano does not depend on an assessment of whether the defendant was aware of the basis for the claim at a previous time—the trial court found credible Solano’s testimony that he was unaware his appeal had not been filed. Id. ¶ 12. Nor does it address whether Rule 32.4(a)(3)(B) hinges on when a defendant knew the legal and factual underpinnings of a claim—or instead when the defendant concluded the claim could be raised in a post-conviction proceeding. Here, where the petitioner delayed twelve years in raising his claim, the passage of time becomes a more pivotal factor in assessing reasonableness of any delay. Accordingly, the time window within which Delich could have reasonably discovered the basis for his claim must be central to our analysis.

¶10 Delich insists that the point from which we evaluate his reasonableness is the point at which he determined he could raise the GEI defense under Rule 33.1(h).

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Bluebook (online)
State of Arizona v. David Nikolas Delich, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-arizona-v-david-nikolas-delich-arizctapp-2025.