Arizona Constitution Article 2 Section 30 Example Case
In State v. Maldonado, 223 Ariz. 309,15-18, 223 P.3d 653, 655-56 (2010), the trial court had erroneously entered a judgment of guilt against a defendant who had never been properly charged. 223 Ariz. 309,10-11, 15, 223 P.3d at 655.
That judgment was therefore obtained in violation of article II, 30 of the Arizona Constitution, a provision that expressly bars felony prosecutions in the absence of an indictment or information. See Maldonado, 223 Ariz. 309,11, 223 P.3d at 655.
Yet, the Arizona Supreme Court held the court had not exceeded its subject matter jurisdiction in entering the judgment because article II, 30 did not "by its terms address jurisdiction" and because article VI, 14(4) of the Arizona Constitution specifically provides superior courts subject matter jurisdiction over felony criminal matters. Maldonado, 223 Ariz. 309,19-21, 223 P.3d at 657.