State v. Chatfield

CourtCourt of Appeals of Arizona
DecidedMay 13, 2026
Docket1 CA-CR 25-0475 PRPC
StatusUnpublished
AuthorAndrew M. Jacobs

This text of State v. Chatfield (State v. Chatfield) 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 v. Chatfield, (Ark. Ct. App. 2026).

Opinion

NOTICE: NOT FOR OFFICIAL PUBLICATION. UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

STATE OF ARIZONA, Respondent,

v.

ANGELA M. CHATFIELD, Petitioner.

No. 1 CA-CR 25-0475 PRPC FILED 05-13-2026

Petition for Review from the Superior Court in Maricopa County No. CR2022-112423-001 The Honorable Margaret B. LaBianca, Judge

REVIEW GRANTED; RELIEF DENIED

COUNSEL

Maricopa County Attorney’s Office, Phoenix By Philip D. Garrow Counsel for Respondent

DwaneCates.Com, PLLC, Phoenix Dwane M. Cates Counsel for Petitioner

MEMORANDUM DECISION

Presiding Judge Andrew M. Jacobs delivered the decision of the Court, in which Judge Brian Y. Furuya and Judge James B. Morse Jr. joined. STATE v. CHATFIELD Decision of the Court

J A C O B S, Judge:

¶1 Angela Chatfield petitions this court for review from the dismissal of her notice of post-conviction relief filed under Arizona Rule of Criminal Procedure (“Rule”) 33. We grant review of her petition but deny the relief she requests.

FACTUAL AND PROCEDURAL HISTORY

¶2 Chatfield pled guilty to one count of facilitation of fraudulent schemes and artifices. On February 14, 2024, the superior court sentenced her to three years of supervised probation. Restitution was left open to be determined, and after multiple continuances, the restitution hearing was scheduled for September 2025.

¶3 Before the restitution hearing, Chatfield moved to preclude expert testimony. The victims opposed Chatfield’s motion, arguing: (1) the Arizona Rules of Evidence do not apply at restitution hearings; and (2) Chatfield’s plea agreement specifically provided the court was not bound by the rules of evidence during sentencing, which includes restitution proceedings. On July 23, 2025, the court denied Chatfield’s motion, reasoning that “[t]he restitution hearing is to the bench, not a jury, making a separate hearing regarding the reliability of an expert opinion and preclusion unnecessary.”

¶4 On August 22, 2025, Chatfield filed a notice seeking post- conviction relief (“Notice”) under Rule 33. Her Notice claimed she reasonably believed that she would be able to fully litigate the restitution claims through evidentiary objections and a Daubert hearing challenging the victims’ expert witness, and that she didn’t know she waived those rights by entering into the plea agreement. Chatfield thus argued her plea was not knowingly, voluntarily, or intelligently made, in violation of the both the United States and Arizona constitutions and the Arizona Rules of Criminal Procedure. See Ariz. R. Crim. P. 33.1(a).

¶5 Chatfield acknowledged her Notice was untimely because she filed it more than 90 days after the oral pronouncement of her sentence. But she argued the delay was not her fault because the basis of her claim — that her plea was involuntary because she did not know sentencing included restitution proceedings — was “recently discovered,” thus excusing the untimeliness under Rule 33.4(b)(3)(B).

¶6 The superior court summarily dismissed Chatfield’s Notice as untimely and insufficient. The court concluded Chatfield failed to

2 STATE v. CHATFIELD Decision of the Court

adequately explain why her Notice was filed untimely. It found her “[v]ague statements” could not justify Rule 33.1(f) relief because she did “not specify when she learned the rules did not apply, how soon thereafter she sought Rule 33.1(f) relief,” or “why she and counsel could not have identified this factor in the exercise of reasonable diligence within 90 days after sentencing.”

¶7 The superior court found her Rule 33.1(a) claims untimely and barred for the same reasons. Further, the court concluded Chatfield’s constitutional claims were insufficient to warrant relief. It found Chatfield “signed the plea agreement, initialed each paragraph, and agreed that counsel had explained it to her,” and explained that “Arizona law gave [Chatfield] and her counsel notice that the Arizona Rules of Evidence would not be enforced in the restitution proceeding irrespective of the plea agreement’s terms.” The court dismissed Chatfield’s Notice because she had to “assert substantive claims and adequately explain why the claims are untimely,” but had failed to do so.

¶8 Chatfield timely petitioned for review. We exercise our discretion to grant review. See Ariz. Const. art. 6, § 9; A.R.S. § 13-4239(G); Ariz. R. Crim. P. 33.16(k).

DISCUSSION

¶9 We review the superior court’s summary denial of post- conviction relief for an abuse of discretion: here, either legal error or an inadequate investigation of the facts needed to support the decision. State v. Harden, 228 Ariz. 131, 132 ¶ 3 (App. 2011). Chatfield bears the burden of establishing the superior court abused its discretion. See State v. Poblete, 227 Ariz. 537, 538 ¶ 1 (App. 2011). We review the superior court’s interpretation of the Arizona Rules of Criminal Procedure de novo. State v. Macias, 249 Ariz. 335, 339 ¶ 8 (App. 2020).

¶10 Rule 33.1 lists eight grounds for post-conviction relief, which proceed under two different timelines. Notices asserting claims under Rule 33.1(a), which covers “most traditional post-conviction claims,” Ariz. R. Crim. P. 33.1(a) cmt., including constitutional claims, must be filed “within 90 days after the oral pronouncement of sentence.” Ariz. R. Crim. P. 33.4(b)(3)(A). But the court must excuse an untimely Rule 33.1(a) notice if “the defendant adequately explains why the failure to timely file a notice was not the defendant’s fault.” Ariz. R. Crim. P. 33.4(b)(3)(D).

¶11 By contrast, notices asserting claims under Rules 33.1(b) through (h) are not subject to the 90-day timeline set forth in Rule

3 STATE v. CHATFIELD Decision of the Court

33.4(b)(3)(A), they need only be filed “within a reasonable time after discovering the basis for the claim.” Ariz. R. Crim. P. 33.4(b)(3)(B).

I. The Court Did Not Abuse its Discretion by Dismissing Chatfield’s Claims as Untimely.

¶12 Chatfield argues the court erred by dismissing her claims as untimely. She claims her Notice was timely under Rule 33.4(b)(3)(D) and Rule 33.1(f) “because the failure to file earlier was not [her] fault,” and that she acted promptly to assert her rights after discovering her own error. Her arguments under both rules fail, as we next explain.

A. The Superior Court Did Not Err in Dismissing Chatfield’s Claims as Untimely in Light of Rule 33.4(b)(3)(D).

¶13 Chatfield’s claims are constitutional, so they fall within Rule 33.1(a). The court reviewed Chatfield’s conclusory statements that she was blameless for her late filing and concluded she did not adequately explain why her failure to timely file a notice was not her fault. See Ariz. R. Crim. P. 33.4(b)(3)(D). Though her Petition states in some detail how and when she discovered her claims with her new counsel, Chatfield’s Notice did not provide this information to the superior court. We cannot say that court abused its discretion by dismissing Chatfield’s Notice as untimely.

B. Rule 33.1(f) Does Not Make Chatfield’s Claim Timely, and Is Not a Substantive Ground For Relief.

¶14 Chatfield also argues her claim was timely in light of Rule 33.1(f), but that rule simply mirrors the legal standard set forth in Rule 33.4(b)(3)(D). Compare Ariz. R. Crim. P. 33.1(f) (making finding that “the failure to timely file a notice of post-conviction relief was not the defendant’s fault” a ground for relief), with Ariz. R. Crim. P.

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Related

State v. Fancher
818 P.2d 251 (Court of Appeals of Arizona, 1991)
State v. Harden
263 P.3d 680 (Court of Appeals of Arizona, 2011)
State v. Poblete
260 P.3d 1102 (Court of Appeals of Arizona, 2011)
Perini Land & Development Co. v. Pima County
825 P.2d 1 (Arizona Supreme Court, 1992)
State v. Estrada
34 P.3d 356 (Arizona Supreme Court, 2001)
State v. Quijada
439 P.3d 815 (Court of Appeals of Arizona, 2019)
State v. MacIas
469 P.3d 472 (Court of Appeals of Arizona, 2020)
State of Arizona v. Beau John Greene
527 P.3d 322 (Arizona Supreme Court, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Chatfield, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-chatfield-arizctapp-2026.