State v. Watkins

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UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL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, Appellee,

v.

CONNIE KAY WATKINS, Appellant.

No. 1 CA-CR 25-0471
FILED 09-23-2026

Appeal from the Superior Court in Mohave County
No. CR-2025-00147
The Honorable Derek C. Carlisle, Judge

AFFIRMED

COUNSEL

Arizona Attorney General’s Office, Phoenix
By Eric Knobloch
Counsel for Appellee

Jill L. Evans Attorney at Law, Flagstaff
By Jill L. Evans
Counsel for Appellant

MEMORANDUM DECISION

Presiding Judge Andrew M. Jacobs delivered the decision of the Court, in
which Judge Daniel J. Kiley and Chief Judge Randall M. Howe joined.

STATE v. WATKINS
Decision of the Court

J A C O B S, Judge:

¶1 Connie Watkins appeals her convictions and concurrent one-
year sentences for two counts of forgery. She argues the record didn’t
support the convictions because the bills she presented were labeled as fake
money (here, motion-picture currency) and were thus neither forged
instruments nor instruments containing false information. For the
following reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

A. Watkins Uses One Fake Bill and Attempts to Use Another
at Dollar General, Leading to Forgery Charges.

¶2 On February 6, 2025, Connie Watkins obtained several bills
resembling $100 currency from an acquaintance. Watkins testified the
acquaintance gave her the fake bills in appreciation for her efforts picking
up trash near local businesses. She possessed the fake bills for an hour and
a half before going to a Dollar General store in Lake Havasu City.

¶3 Watkins picked out several items at the store and presented
one of the fake bills as payment. The receipt showed that she bought $41.63
in merchandise and got $58.37 in change from the fake bill.

¶4 Cashier Dina Almaraz testified she “felt the paper was
wrong” when Watkins handed her the bill. But customers were waiting,
and Dina was “kind of in a hurry,” so she placed the bill in the register and
completed the transaction. Dina estimated she handled the bill for “only
like a couple of seconds.” After another employee arrived to cover the
register, Dina examined the bill more closely, but by then, Watkins had left.

¶5 The bill resembled a $100 bill but contained several
statements identifying it as fake. Its front stated “FOR MOTION PICTURE
PURPOSES” and “THIS NOTE IS FOR MOTION PICTURE PURPOSES. IT
IS NOT LEGAL TENDER.” The back included the phrases “MOTION
PICTURE PURPOSES,” “IN PROPS WE TRUST,” “PROP MONEY INC.,”
and “PROPMONEY.COM.” Dina testified the bill was thicker than genuine
currency and had “a weird feel.” She wrote “fake,” her initials, the date,
and “a star to identify which bill [she] was taking out to double-check it.”

¶6 About four hours after her first purchase with fake money,
Watkins returned to the store and presented another fake bill of the same
type to try to buy more merchandise. Dina recognized the bill, told Watkins
it was fake, and declined to complete the transaction.

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¶7 Watkins doubled down. She said the bills “were not fake”
and showed Dina more fake bills. As Watkins fanned them out, Dina could
see “MOTION PICTURE” printed on them. Watkins asked Dina to return
the bill she had presented, but Dina explained that store procedure required
her to retain it and notify her manager. Dina described Watkins as “very
polite” during the encounter.

¶8 After Watkins left, Dina wrote a notation identifying
“Connie” and recording that she had tried to pass a “fake” $100 bill. Dina
then notified her manager and contacted the police. She also “gave them
the fake bill” when they arrived.

¶9 On February 13, 2025, a grand jury charged Watkins with four
offenses, including three counts of forgery arising from the Dollar General
transactions and one count of possession of drug paraphernalia. Before
trial, the State moved to dismiss Count 4, relating to drug possession, and
the superior court later dismissed that count with prejudice.

¶10 The court also conducted competency proceedings under
Arizona Rule of Criminal Procedure (“Rule”) 11. Based on the submitted
evaluations, the court found Watkins competent to stand trial.

B. The Parties Present Competing Accounts of the
Transactions at Trial.

¶11 The case proceeded to a one-day jury trial in September 2025.
Dina testified about both transactions and identified the two bills Watkins
presented. The State introduced surveillance videos of a person entering
the store and selecting merchandise and a nine-second recording of the
second transaction at the register. In rebuttal of Watkins’ anticipated
testimony that Dina didn’t handle one of the transactions, Dina testified she
handled both transactions and that the male employee visible in the
surveillance recording of the second checkout didn’t accept a bill from
Watkins. The State didn’t introduce footage of the first checkout.

¶12 Frank Mueller, an investigator with the Mohave County
Attorney’s Office, examined the bills at trial. Mueller testified they felt
smoother, lighter, and possibly thinner than genuine currency, bore the
same serial number, and repeatedly stated that they were for “MOTION
PICTURE PURPOSES.” He described the bills as “easy” to spot. Mueller
became involved in the case during trial preparation.

¶13 Watkins testified she believed the bills were genuine. She
explained she wasn’t wearing her reading glasses and couldn’t read

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“medium and small print” without them. She also testified that she
believed the bills were “normal” based on their texture and weight and her
prior experience working at a credit union. Watkins acknowledged she had
handled money during ten or so years of employment at a credit union and
was familiar with the appearance and feel of genuine currency.

¶14 Watkins disputed Dina’s account of the first transaction. She
claimed a male cashier handled the transaction and that she asked him to
“make sure” the bill was good before paying. According to Watkins, the
cashier examined the bill, said, “[t]his is good,” placed it in the register, and
gave her change.

¶15 Watkins also estimated her second visit occurred around 4:00
or 4:30 p.m., while the surveillance recording and Dina’s notation reflected
a time of 6:35 p.m. Watkins testified that she believed the first recording
showed her entering the store but didn’t believe the recordings showing a
person at the register depicted her.

C. The Jury Convicts Watkins of Two Counts of Forgery.

¶16 After the State rested, Watkins moved for judgments of
acquittal under Rule 20 for the three remaining counts. The superior court
granted the motion on Count 3, concluding the State hadn’t sufficiently
connected the additional bills admitted at trial to those reportedly seen in
Watkins’ possession at the store. The court denied the motion as to Counts
1 and 2 and submitted those forgery charges to the jury.

¶17 The jury found Watkins guilty of both counts of forgery. In
the aggravation phase, the jury found that the offenses occurred on separate
occasions and were committed in expectation of receiving something of
pecuniary value. It also found that the victim suffered financial harm as to
Count 1 but not as to Count 2.

¶18 At sentencing, the superior court observed that “from a long
ways away, or just glancing at the bills, they look like they are real $100
bills,” but that “even a cursory inspection” revealed they weren’t genuine
because they stated “For Motion Pictures Only” and “[n]ot legal tender,”
among other differences. The court gave no weight to the aggravating
factors and found that Watkins’ impaired ability to appreciate the
wrongfulness of her actions or conform her conduct to the law and her lack
of prior felony convictions to be mitigating circumstances.

¶19 The court imposed concurrent, mitigated one-year prison
terms, with 251 days of presentence-incarceration credit, followed by

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community supervision. It also ordered Watkins to pay $100 in restitution
and directed that $58 seized by police be applied toward that amount.
Watkins timely appealed. We have jurisdiction. Ariz. Const. art. 6, § 9;
A.R.S. § 12-120.21(A)(1); A.R.S. §§ 13-4031, -4033(A)(1).

DISCUSSION

I. Substantial Evidence Supports Watkins’ Forgery Convictions
Because the Bills Contained False Information and She Presented
Them with Intent to Defraud.

¶20 Watkins argues insufficient evidence supports her forgery
convictions because the bills were prominently labeled as motion-picture
currency and therefore were neither “forged instrument[s]” nor
instruments “contain[ing] false information.” The State responds that the
bills satisfied both alternatives under A.R.S. § 13-2002(A)(3), since they: (1)
were forged instruments because they appeared to be genuine $100 bills at
a glance; and (2) contained false information because they represented that
they were worth $100. We focus our analysis on alternative (2).

¶21 We review de novo both the interpretation of a criminal statute
and the sufficiency of the evidence supporting a conviction. State v. Pena, 235 Ariz. 277, 279 ¶ 5 (2014). In interpreting a statute, we apply its plain
language in context. State v. Serrato, 259 Ariz. 493, 497 ¶ 16 (2025) (quoting
In re Drummond, 257 Ariz. 15, 18 ¶ 5 (2024)). When reviewing the sufficiency
of evidence, we determine only if substantial evidence supports the
verdict—that is, evidence that “reasonable persons could accept as
sufficient to support a guilty verdict beyond a reasonable doubt.” Pena, 235
Ariz. at 279 ¶ 5 (quoting State v. Hausner, 230 Ariz. 60, 75 ¶ 50 (2012)). We
view the evidence in the light most favorable to sustaining the verdict and
do not reweigh the evidence. State v. Guerra, 161 Ariz. 289, 293 (1989) (citing
State v. Tison, 129 Ariz. 546, 552 (1981)).

¶22 “A person commits forgery if, with intent to defraud, the
person . . . [o]ffers or presents, whether accepted or not, a forged instrument
or one that contains false information.” A.R.S. § 13-2002(A)(3). Consistent
with the statute, the court instructed the jury that forgery required proof
that Watkins, “with the intent to defraud, offered or presented, whether
accepted or not, a forged instrument or one containing false information.”

A. The Bills Contained False Information.

¶23 A written instrument “that contains false information” may
support a conviction for forgery. A.R.S. § 13-2002(A)(3). Our supreme

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court has recognized that A.R.S. § 13-2002 is broader than traditional
forgery because it encompasses “not only ‘forged’ instruments . . . but also
documents merely containing ‘false information.’” Moreno v. Jones, 213
Ariz. 94, 99 ¶ 27 (2006) (comparing A.R.S. § 13–2001(8) with A.R.S. § 13-
2002). The State thus wasn’t required to prove that the bills were forged
instruments if substantial evidence established that they contained false
information.

¶24 The State argues the bills contained false information because
they falsely indicated they were worth “ONE HUNDRED DOLLARS.” We
agree. The bills displayed the denomination “100” in several locations and
incorporated other printed features of genuine $100 currency, including
Benjamin Franklin’s portrait, seal-like designs, and serial numbers. Despite
that, the fake bills weren’t legal tender and weren’t worth $100. Their
printed denomination and currency-like identifiers communicated false
information about their nature and value, as a reasonable jury could (and
apparently did) conclude.

¶25 Watkins responds that the $100 denomination can’t constitute
false information because the bills repeatedly and conspicuously disclosed
they were prop money. She emphasizes that they stated “FOR MOTION
PICTURE PURPOSES,” “THIS NOTE IS FOR MOTION PICTURE
PURPOSES. IT IS NOT LEGAL TENDER,” and “IN PROPS WE TRUST,”
and argues that the bills therefore “were clear that they were in fact NOT
worth anything” and “purported to be NOT genuine.”

¶26 These accurate disclaimers, however, don’t negate the false
information printed elsewhere on the bills. Section 13-2002(A)(3) of the
Arizona Revised Statutes applies to an instrument that “contains false
information”; it doesn’t require every statement on the instrument to be
false or for the instrument to omit information revealing the falsity of
another representation. This reading of the statute is commonsensical, as
Watkins’ suggested reading would let forgers manually conceal disclaimers
as they try to pass fake bills, and allow them to fall back on the disclaimers
if they get caught. See Bridgestone/Firestone N. Am. Tire, L.L.C. v. A.P.S. Rent–
A–Car & Leasing, Inc., 207 Ariz. 502, 506 ¶ 16 (App. 2004) (“[W]e attempt to
read statutes in a ‘common-sense and contextualized’ manner.”) (quoting
Ariz. Libertarian Party v. Schmerl, 200 Ariz. 486, 490 ¶ 11 (App. 2001)); S. Point
Energy Ctr. LLC v. Ariz. Dep’t of Revenue, 257 Ariz. 216, 221 ¶ 13 (App. 2024)
(“We read words within the statutory context and aim to bring about the
plain, logical meaning of a statute unless doing so would bring about an
absurd result.”). Accordingly, the bills could accurately disclose that they
weren’t legal tender while also falsely representing a $100 denomination

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and monetary value under A.R.S. § 13-2002(A)(3). The disclaimers were
therefore evidence the jury could consider in deciding whether the bills
contained false information, but they didn’t preclude that finding as a
matter of law.

¶27 Watkins also emphasizes that the first bill would have been
rejected had Dina examined it carefully and argues that obviously fake prop
money falls outside the forgery statute. The State responds that A.R.S. § 13-
2002(A)(3) expressly applies whether the presented instrument is accepted
or not. We agree with the State. The first bill was accepted after Dina
handled it for only “a couple of seconds,” while Dina examined the second
bill more closely and rejected it. Because A.R.S. § 13-2002(A)(3) expressly
applies “whether accepted or not,” the second bill’s rejection didn’t
preclude a forgery conviction if the bill otherwise contained false
information and Watkins presented it with intent to defraud.

¶28 Watkins’ principal argument concerning the statutory
definitions is that a “forged instrument” must be falsely made, completed,
or altered, and that an altered instrument must “falsely appear[] or
purport[] to be in all respects an authentic creation of its ostensible maker
. . . .” A.R.S. § 13-2001(5), (8). She argues the bills couldn’t satisfy that
requirement because their disclaimers openly identified them as props. The
State counters that “appears” and “purports” are distinct: even if the bills
didn’t purport to be genuine in their written disclaimers, their appearance
could still resemble genuine currency closely enough to satisfy the statute.
Watkins replies that the bills did not “falsely appear to be in all respects”
genuine because even a brief examination revealed they were prop money.

¶29 We need not resolve that dispute. The definitions Watkins
invokes govern whether the bills were “forged instrument[s].” See A.R.S. §
13-2001(5), (8). They do not limit A.R.S. § 13-2002(A)(3)’s separate
alternative covering an instrument “that contains false information.”
Applying the “falsely appears or purports” requirement to that alternative
would effectively collapse “one that contains false information” into
“forged instrument” and deprive the former language of independent
effect. We interpret statutes in context and avoid constructions that render
statutory language superfluous. Serrato, 259 Ariz. at 497 ¶ 16. Because
substantial evidence established that the bills contained false information,
we need not decide whether their visual resemblance to genuine currency
also made them forged instruments.

¶30 For the same reason, we need not decide whether the out-of-
state counterfeit cases discussed by the parties compel a different

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conclusion about whether these bills qualify as forged instruments. The
State cites Joyce v. Commonwealth, 82 Va. App. 519, 527–28 (2024), and State
v. Scott, 339 So. 3d 713, 716–17 (La. 2022) but argues their governing forgery
provisions differ from Arizona’s. Watkins responds that those cases
support her position because each involved prop or counterfeit currency
that didn’t purport to be genuine, and she additionally relies on federal
counterfeit cases addressing whether an instrument sufficiently resembles
genuine currency. Those authorities concern whether an instrument
qualifies as forged or counterfeit. Because A.R.S. § 13-2002(A)(3)
independently encompasses instruments containing false information, they
don’t alter our conclusion on that statutory alternative.

B. Substantial Evidence Supports the Finding That Watkins
Intended to Defraud the Store.

¶31 Watkins doesn’t principally challenge the intent element;
rather, she acknowledges evidence of intent to defraud but characterizes it
as disputed. The State maintains the evidence permitted the jury to find
fraudulent intent from Watkins’ conduct during the two transactions.
Intent may be established through circumstantial evidence, including a
defendant’s conduct and statements. State v. Bearup, 221 Ariz. 163, 167 ¶ 16
(2009) (quoting State v. Routhier, 137 Ariz. 90, 99 (1983)).

¶32 Substantial evidence supports the jury’s findings. After
presenting the first bill and obtaining merchandise and change, Watkins
returned several hours later and presented another bill of the same type.
The bills repeatedly identified themselves as being for “MOTION PICTURE
PURPOSES,” and Watkins had approximately ten years of experience
handling genuine currency while working at a credit union. When Dina
told Watkins the second bill was fake, Watkins maintained the bills “were
not fake,” displayed other similar bills, and asked Dina to return the bill she
had presented. From Watkins’ repeated presentation of the bills, her
experience handling genuine currency, and her conduct during the second
transaction, the jury could reasonably infer that Watkins knew the bills
weren’t genuine and nevertheless presented them intending that Dollar
General accept them as $100 currency. Watkins points to her own contrary
testimony to challenge the jury’s verdict, but we “do not reweigh the jury’s
credibility determinations” on appeal. Valdez v. Delgado, 254 Ariz. 495, 500
¶ 18 (2019) (citing Kuhnke v. Textron, Inc., 140 Ariz. 587, 591 (1984)).

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CONCLUSION

¶33 We affirm.

MATTHEW J. MARTIN • Clerk of the Court
FILED: JR

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