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The State was not required to prove she intended to break the law, only that she “knowingly, voluntarily, entered or remained” while she “was aware that [her] entry or remaining was unlawful.” (noting the 3 STATE v. PARRA CARRANZA Decision of the Court defendant’s awareness that entry or remaining was unlawful is a distinct element from “knowingly”

¶16 Rule 609(a)(2) allows for the admission of a prior misdemeanor conviction “only if the conviction is for an offense which involved an element of deceit or falsification.” -29 (1981).

-27 & n.1 (1981) (where jury verdict for Class 6 undesignated felony was designated a misdemeanor at sentencing, “it is clear that the .

d the defendant steadfastly refused to implicate other participants); contra Green, 200 Ariz. at 501, ¶ 22 (concluding error in admission of prior convictions as impeachment evidence was not harmless where the evidence was entirely testimonial, the defendant denied the charge, and the juror questions suggested the existence of defendant’s past convictions affected their verdict); (concluding error in admission of prior convictions as impeachment evidence was not harmless where the defendant “int

¶ 11 (App. 2013) ("[A] defendant's forced entry into a structure permits a jury to infer that defendant had the requisite specific intent for burglary.") ().

§ 13-1802(A)(5) ; State v. Malloy , , 127, , 317 (1981) ("the phrase 'dishonesty or false statement' should be construed narrowly to include only those crimes involving some element of deceit, untruthfulness, or falsification," and not crimes such as theft or robbery); see also State v. Winegardner , , ¶ 17, (2018

¶20 The Arizona Supreme Court has held that “[c]riminal trespass is not necessarily a lesser included offense of burglary.” (citations omitted) (noting that “Arizona courts have consistently held that criminal trespass is not a lesser-included offense of burglary,” and that “[t]he legislative amendment [of the definition of “knowingly

¶ 14 In State v. Malloy, our supreme court determined the “phrase ‘dishonesty oi-false statement’ ” contained in the contemporaneous version of Rule 609(a)(2), Ariz. R. Evid., “should be construed narrowly to include only those crimes involving some element of deceit, untruthfulness, or falsification.”

(determining jury “could have found that the [defendant] had the specific intent necessary to commit burglary in the third degree from the fact that he broke the window.”); (explaining that intent to commit theft can be proven by circumstantial evidence and in

¶15 Upon further study, which held that criminal trespass is not a lesser included offense of burglary.

See State v. Malloy, 131 Ariz. 125, 130

3A John H. Wigmore, et al., Evidence § 520, at 729-30 (James H. Chadbourn ed., 1970); , (limiting the scope of Rule 609(a)’s "dishonesty or false statement” provision to “crimes involving some element of deceit, untruthfulness, or falsification.”).

In State v. Malloy, 131 Ariz. 125, the defendant had previously been convicted of third degree burglary, a class 6 felony.

Consistent with this general rule, we have observed that “a major crime entails such an injury to and disregard of the rights of other persons that it can reasonably be expected the witness will be untruthful if it is to his advantage.” , ( , ).

lesser offense[ ] ha[ve] been.”

(because the perpetrator of a criminal act has demonstrated such a lack of scruples as to show a willingness to give false testimony, all felonies have some probative value in determining credibility).

639 P.2d *283 315, 319 (1981).