State v. Herrera

CourtCourt of Appeals of Arizona
DecidedJuly 13, 2026
Docket1 CA-CR 26-0012 PRPC
StatusUnpublished
AuthorBrian Y. Furuya

This text of State v. Herrera (State v. Herrera) 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. Herrera, (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 UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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.

ROBERT JOE HERRERA, Petitioner.

No. 1 CA-CR 26-0012 PRPC FILED 07-13-2026

Petition for Review from the Superior Court in Maricopa County No. CR2019-140592-001 The Honorable Max H. Covil, Judge

REVIEW GRANTED; RELIEF DENIED

COUNSEL

Maricopa County Attorney’s Office, Phoenix By Robert E. Prather Counsel for Respondent

Robert Joe Herrera, Phoenix Petitioner STATE v. HERRERA Decision of the Court

MEMORANDUM DECISION

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

F U R U Y A, Judge:

¶1 Robert Herrera seeks review of the superior court’s dismissal of his untimely post-conviction relief (“PCR”) petition filed under Arizona Rule of Criminal Procedure (“Rule”) 33.1. We grant review but deny relief.

FACTS AND PROCEDURAL HISTORY

¶2 In 2019, a grand jury indicted Herrera for sexual conduct with a minor, molestation (two counts), attempt to commit sexual conduct with a minor, aggravated luring, and sexual exploitation of a minor. Herrera entered into a plea agreement with the State. Under the plea agreement’s terms, Herrera would plead guilty to attempting to commit sexual conduct with a minor, attempting to commit molestation, and attempting to commit sexual exploitation of a minor—all dangerous crimes against children. In return, the parties stipulated to a 7.5-year prison sentence with a lifetime probation tail upon Herrera’s absolute discharge from the Department of Corrections, and the remaining charges would be dismissed, along with pending charges in two other case numbers. The superior court accepted the plea agreement and sentenced Herrera according to the plea agreement’s terms. After sentencing, Herrera signed a notice of his rights to PCR that read, “you must file a Notice of Post-Conviction Relief within 90 days after the oral pronouncement of sentence.” The rights notice also warned Herrera that if he did not “file a Notice Requesting Post-Conviction Relief within the required time, you may lose the opportunity to have the court correct any error that might have occurred in your case.” After serving his prison sentence, Herrera began his probation in February 2026.

¶3 In 2025, Herrera filed a PCR notice. In the notice, Herrera sought to justify his late filing by referring to a series of legal authorities and vaguely claiming that the State concealed the violation of his rights. Herrera did not elaborate on which rights were violated, when he discovered the violation, how soon after the discovery he filed, or why he could not have discovered the violations sooner by exercising reasonable diligence. The superior court found “Defendant thus fails to adequately explain a filing delay in excess of four years.” Nonetheless, the court

2 STATE v. HERRERA Decision of the Court

addressed the issues raised by Herrera when he checked the boxes on the notice form and dismissed the PCR notice.

¶4 Herrera then filed a motion for reconsideration. In the motion, Herrera explained that he was unaware that he signed the notice of rights form and blamed his lawyer for not giving him his papers. The court denied the motion, noting that Herrera had indeed signed the notice of rights form.

¶5 Herrera petitioned this court for review. We have jurisdiction under Arizona Revised Statutes (“A.R.S.”) Section 13-4239(C) and Rule 33.16.

DISCUSSION

¶6 This court will not disturb a superior court’s ruling on a PCR petition absent an abuse of discretion or error of law. State v. Gutierrez, 229 Ariz. 573, 577 ¶ 19 (2012); State v. Macias, 249 Ariz. 335, 340 ¶ 16 (App. 2020). It is the petitioner’s burden to show the superior court abused its discretion by denying the petition for post-conviction relief. State v. Poblete, 227 Ariz. 537, 537 ¶ 1 (App. 2011). We review the court’s legal conclusions de novo. State v. Pandeli, 242 Ariz. 175, 180 ¶ 4 (2017). A defendant must strictly comply with the PCR rules to be eligible for relief. Canion v. Cole, 210 Ariz. 598, 600 ¶ 11 (2005); State v. Carriger, 143 Ariz. 142, 146 (1984) (“Petitioners must strictly comply with Rule 32 or be denied relief.”).

I. Herrera Waived His Claims Under Rule 33.1(a) by Filing His Notice After the Time to File Expired.

¶7 Rule 33.4(b)(3)(A) requires a defendant to file their PCR notice for claims under Rule 33.1(a) within 90 days after sentencing. Rule 33.4(b)(3)(D) allows a court to excuse an untimely filing if the defendant adequately explains why the failure “was not the defendant’s fault.” In State v. Ainsworth, the court held that the without-fault language applies “when a court has not informed a defendant of the right to seek post-conviction relief or when someone else has interfered with a defendant’s attempt to file a timely petition.” 250 Ariz. 457, 459 ¶ 7 (App. 2021).

¶8 Herrera received and signed for his notice rights. The notice specifically explained how to file a notice.

How to File. You must obtain a copy of Form 24(b) (Notice Requesting Post-Conviction Relief) from your attorney, the clerk of the court, or staff at the jail or prison where you are incarcerated. Complete the notice and file it with, or send it

3 STATE v. HERRERA Decision of the Court

to, the clerk of the superior court of the county where you were sentenced. The notice must arrive at the clerk’s office within the time specified in paragraph 2.

See also Ariz. R. Crim. P. 17.2(a)(5) (Before accepting a guilty plea, the court must address the defendant personally and determine that he or she understands the plea, waives the right to an appeal, and the defendant must proceed through PCR under Rule 33.) Herrera’s claim that he did not remember receiving the notice’s admonition does not show that the delay was justified, and the court did not abuse its discretion by denying the Rule 33.1(a) claims.

II. The Remaining Claims Lack Merit, So the Court Did Not Abuse Its Discretion by Denying Them.

¶9 Herrera claimed that (1) the court lacked subject matter jurisdiction (Rule 33.1(b)); (2) his punishment is illegal (Rule 33.1(c)); (3) he will be held in custody beyond the expiration of his sentence (Rule 33.1(d)); and (4) newly discovered and material facts support relief (Rule 33.1(e)). Initially, Herrera did not elaborate on any of these claims in his notice. In his reconsideration motion, he included a memorandum that was not attached to his notice that he claims explained his position. Much of the memorandum is difficult to follow. The parts of the memorandum addressing claims under Rule 33.1(a) are waived because of Herrera’s late filing and will not be further addressed. Herrera’s claims that could fall under Rule 32.1(b)–(e) had to be raised within a reasonable time after he discovered the basis for the claim. Ariz. R. Crim. P. 33.4(b)(3)(B). While it does not appear that Herrera raised the claims within a reasonable time, we nonetheless reject them on their merits.

A. Subject matter jurisdiction

¶10 Under our constitution, the superior court has original jurisdiction of “[c]riminal cases amounting to felony.” Ariz. Const. art. VI, § 14(4); see also A.R.S. § 12–123(A) (“The superior court shall have original and concurrent jurisdiction as conferred by the constitution . . . .”). Because the State prosecuted felony charges against Herrera, the superior court had subject matter jurisdiction in this case.

B.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State of Arizona v. Phil Gutierrez
278 P.3d 1276 (Arizona Supreme Court, 2012)
State v. Peek
195 P.3d 641 (Arizona Supreme Court, 2008)
Canion v. Cole
115 P.3d 1261 (Arizona Supreme Court, 2005)
State v. Carriger
692 P.2d 991 (Arizona Supreme Court, 1984)
State v. Wagstaff
794 P.2d 118 (Arizona Supreme Court, 1990)
State v. Poblete
260 P.3d 1102 (Court of Appeals of Arizona, 2011)
Demarce v. Willrich
56 P.3d 76 (Court of Appeals of Arizona, 2002)
State of Arizona v. Darrel Peter Pandeli
394 P.3d 2 (Arizona Supreme Court, 2017)
State v. MacIas
469 P.3d 472 (Court of Appeals of Arizona, 2020)

Cite This Page — Counsel Stack

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