The Arizona Supreme Court reversed and remanded a criminal conviction in *State of Arizona v. John Logan Brown*, addressing key questions about self-defense laws and what constitutes a residential structure under Arizona statute. The decision, filed Oct. 7, 2025, stemmed from a case where Brown was charged with three counts of aggravated assault but claimed he acted in self-defense.
Brown's case originated in Pima County Superior Court under Judge Brenden J. Griffin. During trial, Brown requested several justification jury instructions related to his self-defense claim. However, the superior court denied Brown's request for instructions on the defense of residential structure under A.R.S. § 13-418, the defense of premises under A.R.S. § 13-407, and the presumption that applies to these defenses under A.R.S. § 13-419.
The case presented two critical legal questions that the Arizona Supreme Court needed to resolve. First, the court had to determine whether a bedroom within a condominium constitutes a 'residential structure' under Arizona law. Second, the court considered the scope and application of justification statutes that presume an individual lawfully uses force when defending against an unlawful entry into a residential structure.
Justice Beene authored the majority opinion, joined by Vice Chief Justice Lopez and Justices Bolick, Montgomery, King, and retired Justice Berch. Chief Justice Timmer dissented from the majority decision, though the specific grounds for dissent were not detailed in the available court documents.
The case attracted significant attention from civil liberties organizations. The American Civil Liberties Union Foundation of Arizona, represented by attorney Jared G. Keenan, filed amicus curiae briefs supporting Brown's position. Arizona Attorneys for Criminal Justice also joined as amici curiae, indicating the broader implications legal professionals saw in the case's outcome.
The state was represented by Arizona Attorney General Kristin K. Mayes' office, with Deputy Solicitor General Alice M. Jones leading the criminal appeals section. Assistant Attorneys General Casey D. Ball and Amy M. Thorson argued the state's position. Brown was represented by the Pima County Legal Defender's office, with James L. Fullin serving as the Legal Defender and Assistant Legal Defender Alex D. Heveri arguing on Brown's behalf.
The case traveled through multiple levels of Arizona's court system before reaching the state's highest court. Initially decided in Pima County Superior Court, the case was appealed to the Arizona Court of Appeals, Division Two, where it was assigned case number 2 CA-CR 23-0138. The Court of Appeals issued a memorandum decision that was 'vacated in part, affirmed in part' by the Arizona Supreme Court's final ruling.
The Supreme Court's decision to reverse and remand suggests that significant legal errors occurred in the lower court proceedings, particularly regarding the jury instructions that were denied. When a court reverses and remands, it typically means the appellate court found legal errors that require the case to be sent back to the trial court for further proceedings consistent with the higher court's ruling.
This case highlights the complexity of self-defense laws in Arizona, particularly regarding the defense of one's home or residential space. Arizona's justification statutes provide specific protections for individuals who use force to defend their residential structures, but the application of these laws can depend heavily on how courts interpret terms like 'residential structure.'
The question of whether a bedroom within a condominium qualifies as a residential structure under A.R.S. § 13-418 has practical implications for how self-defense cases are prosecuted and defended throughout Arizona. The presumption statute under A.R.S. § 13-419 is particularly important because it shifts the legal burden in favor of defendants who can establish they were defending their residential space from unlawful entry.
The involvement of civil liberties organizations as amici curiae suggests the case's potential impact extends beyond Brown's individual circumstances. The ACLU of Arizona and Arizona Attorneys for Criminal Justice likely viewed the case as having implications for broader self-defense rights and the proper application of Arizona's justification statutes.
With the case now reversed and remanded to Pima County Superior Court, the proceedings will return to the trial level where the court must reconsider the case in light of the Arizona Supreme Court's guidance on residential structure definitions and justification jury instructions. The outcome could influence how similar self-defense cases are handled throughout Arizona's court system.
The dissent by Chief Justice Timmer indicates the legal questions presented were not straightforward, and reasonable judicial minds disagreed on the proper interpretation of Arizona's self-defense statutes in this context.