State v. Chatfield

── State v. Chatfield ── Court: Court of Appeals of Arizona Date: May 13, 2026 Category: General 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 UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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 s