McDonald v. Thomas: Regulating the Governor’s Clemency Power

The Arizona Supreme Court considered whether the Disproportionality Review Act was constitutional and whether commutation was an official act of the governor such that a letter of denial required the governor’s signature and attestation of the secretary of state to be valid. The court held the Act was constitutional and that the letter denying the Board’s unanimous recommendation of McDonald’s sentence was invalid because it was not signed by Governor Symington nor attested by the secretary of state.