Cited by

“[O]nly a reasonable inference of the corpus delicti need exist before a confession may be considered; it need not be proven beyond a reasonable doubt.” (citing cases).

Although the details of a victim’s cause of death tend to be tragic, such evidence is admissible unless presented “for the sole purpose of inflaming the jury.” (noting the facts surrounding a victim’s cause of death are always relevant in a homicide case).

(“[T]he order of proof is within the discretion of the trial court.

(holding gruesome and inflammatory evidence may be admitted if it is material to some aspect of the case so long as it is not admitted for the sole purpose of inflaming the jury).

¶ 40, (stating that photographs must not be introduced “for the sole purpose of inflaming the jury” ( )).

(citing Smith v. United States, 348 U.S. 147, 152 (1954), ), “[o]nly a reasonable inference of the corpus delicti need exist before a confession may be considered,” Gillies, 135 Ariz. at 506 ( STATE v. WOODS Decision of the Court 170 (1982)).

STANDARD OF REVIEW ¶8 In reviewing orders on motions to suppress evidence, we consider only evidence presented during the suppression hearing, ¶ 4 (App. 2013), and view the facts in the light most favorable to the trial court’s ruling

We look only at the evidence presented to the trial court during the suppression hearing, ¶ 4 (App. 2013), and view the facts in the light most favorable to the trial court’s ruling, ¶ 2 (App. 2010).

of Maricopa, ¶ 13 , ( , and Adolfson v. United States, 159 F.2d 883, 888 (9th Cir.1947)).

4 STATE v. ROBINSON Decision of the Court the quantum of proof beyond a reasonable doubt.” Jones, 198 Ariz. at 22, ¶ 12, 6 P.3d at 327 ( ).

The two murder convictions stemming from a single death are multiplicitous because premeditated murder and felony murder are not separate crimes—“they are simply two forms of first-degree murder.” ¶ 50, (“[I]n Arizona, first- 10 degree murder is only one crime whether it is premeditated murder or a felony murder.”); ¶ 7, (recognizing that the majority of jurisdictions that have ad

supplemented by P.2d 642 (1983).

(“[I]n Arizona, first-degree murder is only one crime whether it is premeditated murder or a felony murder.”); , (“It is within the sound discretion of the prosecutor to determine whether to file criminal charges and which

Photographs must not be introduced “for the sole purpose of inflaming the jury,” State v. Gerlaugh, 134 Ariz. 164, 169, but “[t]here is nothing sanitary about murder” and sometimes gruesome photographs properly will be introduced

¶ 5 When reviewing a trial court’s denial of a motion to suppress, we consider only the evidence presented at the suppression hearing, , and view it in the light most favorable to upholding the court’s ruling

Photographs may not be admitted “for the sole purpose of inflaming the jury,” State v. Gerlaugh, 134 Ariz. 164, 169, but may be introduced “to show the nature and location of the fatal injury, to help determine the degree or atrociousness of the crime, to corroborate state witnesses, to illustrate or explain testimony, and

Photographs cannot be introduced, however, “for the sole purpose of inflaming the jury.”

Photographs, however, cannot be introduced “for the sole purpose of inflaming the jury.”

-70, -06 (1982); -06, -13 (1983).

and the conviction thereby lack fundamental fairness.’” see also Smith v. United States, 348 U.S. 147, 153, 75 S. Ct. 194, 197 (1954) (purpose of corpus delicti rule is to prevent errors in convictions based on untrue confessions); (same).

before a confession may be considered: it need not be proven beyond a reasonable doubt.”