State v. Wade

CourtCourt of Appeals of Arizona
DecidedOctober 2, 2025
Docket1 CA-CR 23-0421-PRPC
StatusUnpublished

This text of State v. Wade (State v. Wade) 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. Wade, (Ark. Ct. App. 2025).

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 UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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

WILLIAM EARL WADE, JR., Petitioner.

No. 1 CA-CR 23-0421 PRPC FILED 10-02-2025

Petition for Review from the Superior Court in Maricopa County No. CR2018-158411-001, CR2018-121601-001 The Honorable Ronee Korbin Steiner, Judge

REVIEW GRANTED; RELIEF GRANTED IN PART; REMANDED FOR RE-SENTENCING

APPEARANCES

Maricopa County Attorney’s Office, Phoenix By Christine Davis Counsel for Respondent

William Earl Wade, Jr., Winslow Petitioner Pro Se STATE v. WADE Decision of the Court

MEMORANDUM DECISION

Judge Michael J. Brown delivered the decision of the Court, in which Presiding Judge Anni Hill Foster and Judge Paul J. McMurdie joined.

B R O W N, Judge:

¶1 Petitioner William Earl Wade, Jr. seeks review of the superior court’s order denying his claims for post-conviction relief (“PCR”) under Arizona Rule of Criminal Procedure (“Rule”) 32. For the following reasons, we grant review, grant relief in part, and remand for re-sentencing.

BACKGROUND

¶2 In May 2018, police officers arrested Wade after discovering a plastic baggie containing methamphetamine in his pocket while searching him during a non-drug-related investigation. State v. Wade, 1 CA-CR 20- 0096, 2021 WL 709765, at *1, ¶ 2 (Ariz. App. Feb. 23, 2021) (mem. decision). In December 2018, while on release from that arrest, Wade was arrested after police officers discovered a glass pipe and a baggie containing methamphetamine in his pocket. State v. Wade, 1 CA-CR 20-0095, 2021 WL 710187, at *1, ¶ 2 (Ariz. App. Feb. 23, 2021) (mem. decision).

¶3 Following a trial on the May charge, the jury found Wade guilty of possession or use of dangerous drugs, a class 4 felony. Wade, 1 CA-CR 20-0096, at *1, ¶ 5. Another trial was held on the December charges, at which Wade testified and admitted to a 2016 felony conviction for possession of marijuana. The jury found Wade guilty of possession or use of dangerous drugs, a class 4 felony, and guilty of possession of drug paraphernalia, a class 6 felony. Wade, 1 CA-CR 20-0095, at *1, ¶ 3. The jury also found an aggravating circumstance because the December offenses were committed while Wade was released on his own recognizance after the May arrest. A.R.S. § 13-708(D). The State did not seek to prove any of Wade’s other prior convictions.

¶4 The superior court held a joint sentencing hearing for both offenses. Relying on the admitted prior conviction for marijuana possession, the court sentenced Wade as a category two repeat offender to four-and-a-half years’ imprisonment for the May offense. A.R.S. § 13-703(I). And noting both the marijuana conviction and the conviction for the May

2 STATE v. WADE Decision of the Court

offense, the court sentenced him as a category three repeat offender for the December offenses as follows: a “presumptive term of 10 years plus 2 years as a result of his being on release, for a total of 12 years” for possession or use of a dangerous drug and a “presumptive term of 3.7 years plus 2 years as a result of his being on release, total[ing] 5.75 years” for possession or use of drug paraphernalia. The court ordered presentence incarceration credit of 200 days and ordered all sentences to run concurrently. Wade appealed, and this court affirmed but modified his presentence incarceration credit to 202 days. Wade, 1 CA-CR 20-0096, at *2, 5, ¶¶6–8, 26; Wade, 1 CA-CR 20-0095, at *3, ¶ 16.

¶5 In November 2020, Arizona voters passed Proposition 207, which decriminalized possession of small amounts of marijuana, A.R.S. § 36-2852, and provided an avenue for expungement of previous convictions for possession of marijuana, A.R.S. § 36-2862. Wade successfully petitioned to expunge his 2016 conviction for possession of marijuana. In its response to Wade’s petition for expungement, the State included a motion requesting the superior court to schedule a re-sentencing hearing if the petition was granted because the marijuana conviction “was used to enhance the sentences in those matters.” The court granted the petition for expungement but took no action on the State’s motion, explaining that (1) Wade was free to seek PCR relief under Rule 32 but had not done so, and (2) “re[-]sentencing would not change the outcome given, that there are other convictions on which the Court can rely to maintain the same sentence.” Wade then filed a motion requesting a re-sentencing hearing, which the court denied on the grounds that such a request must be made through a Rule 32 petition.

¶6 In November 2021, Wade filed a pro per notice of PCR and petition for PCR, asserting in part that a significant change in the law affected his sentences. See Ariz. R. Crim. P. 32.1(g) (“Grounds for relief [include] a significant change in the law that, if applicable to the defendant’s case, would probably overturn the defendant’s . . . sentence.”). In February 2022, the superior court appointed counsel to represent Wade during the PCR process. Almost one year later, PCR counsel filed a notice of no colorable claims, explaining that even though the marijuana conviction was expunged, it “would still leave [Wade] with three other priors and thus have no effect on [his] sentence.” Wade then filed a PCR petition in both cases. He raised several issues, including lack of proof of prior convictions, but did not specifically address expungement. The State argued the petitions were procedurally deficient, urging the court to either return them along with orders outlining the deficiencies, or to summarily dismiss the

3 STATE v. WADE Decision of the Court

petitions. In his reply, Wade asserted that the only aggravating factor at sentencing was his now expunged marijuana conviction.

¶7 The superior court denied Wade’s claims for PCR and dismissed his petitions. The court acknowledged expungement of the marijuana conviction but reasoned that Wade “has multiple other allegeable prior felony convictions, which could have been alleged and will be alleged and proven if he was to be re[-]sentenced.”

¶8 Wade timely petitioned this court for review of the denial and dismissal of his claims for PCR. The State did not respond on the merits but instead filed a notice of acknowledgment asserting the petition was “inadequate and did not comply with procedural rules.” We have jurisdiction under A.R.S. § 13-4239(C) and Rule 32.16.

DISCUSSION

¶9 Absent an abuse of discretion, we will not disturb a superior court’s ruling on a petition for post-conviction relief. State v. Gutierrez, 229 Ariz. 573, 577, ¶ 19 (2012). “An abuse of discretion occurs if the PCR court makes an error of law or fails to adequately investigate the facts necessary to support its decision.” State v. Pandeli, 242 Ariz. 175, 180, ¶ 4 (2017). Wade has the burden to show the court abused its discretion. State v. Poblete, 227 Ariz. 537, 538, ¶ 1 (App. 2011).

¶10 Wade argues that he is entitled to re-sentencing because “[t]he only prior discussed or used [at his sentencing] was a possession of marijuana charge.” We agree.

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State v. Nash
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State v. Wade, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-wade-arizctapp-2025.