Cited by

¶11 To be sure, the court has discretion to investigate allegations of juror misconduct, ¶ 56 (2004), and should err on the side of granting an evidentiary hearing to permit an informed ruling

12 STATE v. JAMES Decision of the Court introduced primarily to inflame the jury”); - 09 ¶¶ 62-63 (2004) (superior court properly admitted graphic autopsy photographs as evidence on the disputed time and manner of the victims’ deaths, but abused its discretion by admitting crime-scene photographs and video of the victims’ burned bodies, which were “highly inflammatory” yet “of minimal probative v

“Substantial evidence is that which reasonable persons could accept as sufficient to support a guilty verdict beyond a reasonable doubt.” ¶ 87 (2004).

Substantial evidence to support a conviction is evidence that “reasonable persons could accept as sufficient to support a guilty verdict beyond a reasonable doubt.” ¶ 87 (2004).

¶ 87 (2004) (quotation omitted).

This court views the evidence in the light most favorable to sustaining the verdict, ¶ 87 (2004) (citing cases), testing the sufficiency of the evidence “against the statutorily required elements of the offense,” ¶ 8 (App. 2005).

We review the superior court’s decision on courtroom security measures for an abuse of discretion, ¶ 118 (2008), and will uphold such a decision if supported by the record, ¶ 84 (2004).

Notably, “Arizona has adopted the broad view of the inevitable discovery rule,” and so “the State is not required to demonstrate that police initiated lawful means to acquire evidence prior to its seizure.” ¶ 37 (2004).

This court views the evidence in the light 8 STATE v. DAVIS Decision of the Court most favorable to sustaining the verdict, ¶ 87 (2004) (citing cases), testing the sufficiency of the evidence “against the statutorily required elements of the offense,” ¶ 8 (App. 2005).

¶14 Arizona law has recognized this exception where officers found evidence during an illegal pat-down where the defendant “would have been arrested on independent grounds and the evidence would inevitably have been discovered during a lawful search incident to that arrest,” ¶ 38 (2004), or where officers searched a car without a warrant and found evidence that would have been discovered during an inventory search

¶ 64; ¶¶ 70, 75 (2004) (detective properly testified as expert where training consisted of classes and watching two training videos because, although “this training is not extensive, it is significantly more extensive than the average person has received”).

2 § 22; (“The stated intent of [the Juvenile Justice Initiative] was to make possible more effective and more severe responses to juvenile crime.”).

–88 (1983) (finding color photos of charred body, damaged skull, and exposed 5 STATE v. MEDINA Decision of the Court brain matter inadmissible); –09, ¶¶ 61, 63 (2004) (finding crime scene photos depicting charred and decomposing bodies inadmissible); ¶¶ 30–33 (2002) (finding photos of a minor victim’s genital area and anus inadmissible).