Cited by

Globe Newspaper Co., 457 U.S. at 607; (“[P]rotection of the dignity of the complaining witness in a rape case is a substantial justification for excluding spectators.”); Ariz. R. Crim.

(“A defendant waives his objections to the grand jury proceeding by failing to comply with [Rule 12.9’s] timeliness requirement.”).

Sec., –52 ¶ 19 (App. 2007) ().

Sec., –52 ¶ 19 (App. 2007) ().

Sec., –52, ¶ 19 (App. 2007) ().

Sec., –52, ¶ 19 (App. 2007) (“[W]e affirm the trial court’s order if the facts at trial support the trial court’s findings whether or not each supportive fact is specifically called out by the trial court in its findings.”) ().

¶55 A sanction must be proportional to the disclosure violation, ¶ 155 (2013), and preclusion should be imposed only when less stringent sanctions do not accomplish the “ends of justice.”

For the remaining charges, Wilson has not shown that the court’s (before precluding a witness, courts consider (1) the witness’ importance to the proponent’s case, (2) whether the proposed testimony will surprise or prejudice the opposing party, (3) whether bad faith or willfulness motivated the late disclosure, and (4) any other relevant circumstances.).3 III.

Sec., ¶ 19 (App. 2007) ().

Sec., ¶ 19 (App. 2007) ().

Sec., ¶ 19 (App. 2007) ().

Sec., ¶ 19 (App. 2007) ().

Sec., ¶ 19 (App. 2007) ().

Sec., ¶ 19 (App. 2007) ().

Sec., ¶ 19 (App. 2007) ().

Sec., ¶ 19 (App. 2007) ().

Preclusion should be imposed only if “other less stringent sanctions are not applicable.”

."); ("The trial court, however, should seek to apply sanctions that affect the evidence at trial and the merits of the case as little as possible, since the Rules of Criminal Procedure are designed to implement, and not to impede, the fair and speedy determination of cases.").

Likewise, he claims the trial court abused its discretion in ordering preclusion as a sanction without appropriate consideration of the factors discussed in State v. Smith , , 252

P. 12.9(b) (challenges to grand jury proceedings must be filed within 25 days after arraignment or after the certified transcript and minutes are filed); ("A defendant waives his objections to the grand jury proceeding by failing to comply with the timeliness requirement.").

("A defendant waives his objections to the grand jury proceeding by failing to comply with the timeliness requirement.").

(closing the courtroom to the public but not the press when the rape victim testified).

¶ 59, (“Prohibiting the calling of a witness should be invoked only in those cases where other less stringent sanctions are not applicable to effect the ends of justice.”).

If 18 Although it may have been improper for Officer Repp to testify that Defendant was arrested on an outstanding warrant, , we cannot conclude that the remedial efforts taken by the court immediately following the statement were insufficient to cure the statement’s possible prejudicial impact.