Arias was convicted of murder and the jury sentenced him to death. He moved to modify that sentence, and pointed to a number of mitigating factors, including "possible fetal alcohol syndrome." The trial court denied the motion on the ground that the aggravating circumstances of the crime "far outweigh any mitigating circumstances." 913 P. 2d at 1043.

On appeal the California Supreme Court held that the trial judge, in resolving that motion, was not required to discuss the specifics of the mitigating evidence.