State v. Superior Court (Coronado)

In State v. Superior Court (Coronado), 186 Ariz. 363, 922 P.2d 927 (App. 1996), the adult victim accused her co-worker, Coronado, of sexual assault. Id. at 364, 922 P.2d at 928. Shortly after Coronado was indicted for two counts of sexual assault, the victim committed suicide. Id. at 365, 922 P.2d at 929. After the State listed the decedent's parents as witnesses, defense counsel requested to interview the parents. Id. In response, the State argued that the parents had the right to decline the interviews pursuant to the Victims' Bill of Rights. Id. The trial court ordered the decedent's parents to submit to interviews with defense counsel, and we affirmed, stating: "While the constitutional definition of 'victim' does not explicitly state that a deceased victim must have been killed by the alleged criminal offense in order for a parent to qualify as a victim pursuant to the Victims' Bill of Rights, we think that such a limitation is implied in the language of the constitution." Id. at 365-66, 922 P.2d at 929-30.