State v. Hernandez

CourtCourt of Appeals of Arizona
DecidedMarch 5, 2026
Docket1 CA-SA 25-0288
StatusPublished
AuthorDaniel J. Kiley

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

Opinion

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

STATE OF ARIZONA, Petitioner,

v.

JOSE G. HERNANDEZ, Respondent.

No. 1 CA-SA 25-0288 FILED 03-05-2026

Petition for Special Action from the Superior Court in Maricopa County No. CR2023-007600-001 The Honorable Joshua D. Rogers, Judge

JURISDICTION ACCEPTED; RELIEF GRANTED

COUNSEL

Maricopa County Attorney’s Office, Phoenix By Johnny Jacquez, Quinton S. Gregory Counsel for Petitioner

Maricopa County Public Defender’s Office, Phoenix By Meghan White Counsel for Respondent STATE v. HERNANDEZ Opinion of the Court

OPINION

Judge Daniel J. Kiley delivered the opinion of the Court, in which Judge Brian Y. Furuya joined. Presiding Judge Angela K. Paton specially concurred.

K I L E Y, Judge:

¶1 The Arizona Rape Shield Law, A.R.S. § 13-1421, generally prohibits the admission of evidence of the victim’s prior sexual conduct at a trial for a sex offense. The statute contains a number of exceptions, however, including one for “[e]vidence of specific instances of sexual activity showing the source or origin of . . . trauma.” A.R.S. § 13-1421(A)(2). The parties to this special action agree that this exception applies to physical trauma exhibited by the victim, but dispute whether it applies to mental or emotional trauma as well. Defendant Jose Hernandez argued in the superior court that it does, and the court agreed. Because we conclude otherwise, we accept jurisdiction and grant relief.

FACTS AND PROCEDURAL HISTORY

¶2 Hernandez is charged with multiple felonies in the underlying case, including three allegedly committed against his niece “Brianna” (a pseudonym): two counts of molestation of a child, class 2 felonies and Dangerous Crimes Against Children in violation of A.R.S. §§ 13-705 and -1410, and one count of attempted molestation of a child, a class 3 felony and Dangerous Crime Against Children in violation of A.R.S. §§ 13-705, -1001, and -1410.

¶3 During her forensic interview, Brianna disclosed that she was not only molested by Hernandez, but was also victimized by two other family members on other occasions. One of these family members molested her, she reported, while, on a different occasion, the other attempted to show her pornographic material.

¶4 Hernandez moved under A.R.S. § 13-1421 to admit evidence of Brianna’s allegations against the two other family members, asserting that such evidence was relevant to the accuracy of her memory of the

2 STATE v. HERNANDEZ Opinion of the Court

charged crimes and her identification of the perpetrator.1 Asserting that he and the two other family members are “incredibly similar looking[,]” Hernandez stated that he intends to argue at trial that Brianna’s identification of him as the perpetrator of the charged crimes resulted from “confusion” stemming from her victimization by other family members. Although none of the subsections of Section 13-1421 list “confusion as to the identity of the perpetrator” as an exception to the Rape Shield Law, Hernandez insisted that Brianna’s purported “confusion” fell within the scope of Section 13-1421(A)(2) (“Subsection (A)(2)”), which authorizes the admission of “[e]vidence of specific instances of sexual activity showing the source or origin of . . . trauma.” A.R.S. § 13-1421(A)(2). According to Hernandez, Brianna’s victimization by others offers an “alternate explanation” for her “mental sexual trauma” and constitutes the “source” of her purported “confusion” about the perpetrator’s identity.

¶5 The State opposed Hernandez’s motion, asserting, inter alia, that the “trauma” exception set forth in Subsection (A)(2) applies only to “physical manifestations of specific sexual activity[,]” not the victim’s “mental or emotional trauma[.]”

¶6 The superior court granted Hernandez’s motion, finding that Brianna’s report that she was victimized by two other family members supported Hernandez’s misidentification defense because it “goes to the issue of who committed the alleged abuse and whether the alleged abuse is remembered correctly[.]” Holding that the word “trauma” as used in Subsection (A)(2) is not limited to physical trauma, the court found that evidence of Brianna’s victimization by others supported Hernandez’s claim that the “other two men[,]” and not Hernandez, “caused the trauma” that, in turn, “caused [Brianna] to not remember the incidents correctly.” The State seeks relief from this order by special action. See Ariz. R.P. Spec. Act. 11.

DISCUSSION

¶7 The State asserts that relief by special action is warranted because the superior court erred in interpreting Subsection (A)(2) “to include purely emotional harm[.]” “[A]ll child victims of sexual abuse” suffer emotional harm, the State argues, and the court’s construction of Subsection (A)(2) improperly allows Hernandez to use Brianna’s “general

1 Nonconsensual sexual acts committed against a victim are considered the

victim’s “sexual conduct” for purposes of the Rape Shield Law. See State v. Dixon, 226 Ariz. 545, 554, ¶ 47 (2011).

3 STATE v. HERNANDEZ Opinion of the Court

and nonspecific reports of emotional distress” to “evade” Section 13-1421’s restrictions on the admission of evidence of “a victim’s sexual history[.]” In response, Hernandez argues that the superior court correctly determined that “psychological trauma” falls within Subsection (A)(2)’s “exception to the rape shield[.]”

¶8 The exercise of special action jurisdiction, though “highly discretionary,” Yauck v. West Town Bank & Trust, 259 Ariz. 481, 485, ¶ 12 (App. 2025) (citation omitted), may be appropriate if the aggrieved party has no “equally plain, speedy and adequate” remedy by appeal, Ariz. R.P. Spec. Act. 2(b)(2); State v. Lee, 226 Ariz. 234, 236, ¶ 6 (App. 2011) (accepting special action jurisdiction because a special action was “the only means by which relief may be obtained”). As this Court has long recognized, “accepting special action jurisdiction is particularly appropriate where the welfare of children is involved and the harm complained of can only be prevented by resolution before an appeal.” Dep’t of Child Safety v. Beene, 235 Ariz. 300, 303, ¶ 6 (App. 2014). Further, a special action is a proper vehicle to challenge a ruling compelling the disclosure of information that is alleged to be protected. See Ariz. R.P. Spec. Act. 12(b)(2) (identifying “whether the petition asks the court to resolve questions . . . of legal or evidentiary privileges” as a factor supporting special action jurisdiction); cf. Arpaio v. Figueroa, 229 Ariz. 444, 446, ¶ 5 (App. 2012) (“When the subject of [a] discovery order is privileged or confidential material, it is particularly appropriate to accept [special action] jurisdiction.” (citation modified)). Finally, because the interpretation of statutes and court rules is a question of law reviewed de novo, cases presenting such issues are “particularly appropriate for review by special action.” Yauck, 259 Ariz. at 485, ¶ 12 (citation omitted). For these reasons, we accept special action jurisdiction here.

¶9 The Arizona Rape Shield Law generally prohibits the admission of evidence of the victim’s prior sexual conduct in prosecutions for sexual offenses. A.R.S.

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