Cited by

-68, ¶¶ 19-20 (2005); ¶ 23 (2009) (violations of Rule 13.5(b) "do not fall into [the] category" of structural error).

See State v. Henderson , , 567, ¶ 19, , 607 (2005).

¶35 Although we generally review a trial court's voir dire rulings for abuse of discretion, State v. Patterson , , 273 ¶ 5, , 4 (2012), fundamental error review applies to Bush's constitutional claims because he did not raise them at trial, State v. Henderson , , 567 ¶ 19, , 607 (2005) (noting that "[a] defendant who fails to object at trial forfeits the right to obtain appellate relief except in those rare cases" involving fundamental error).

However, because Appellant did not object to the detective’s testimony, our standard of review is fundamental error, which requires Appellant to “show that the error complained of goes to the foundation of his case, takes away a right that is essential to his defense, and is of such magnitude that he could not have received a fair trial.” ¶ 24 (2005) (citation omitted).

State v. Henderson , , ¶ 18

-68, ¶¶ 18-20 (2005) (explaining that when an issue is preserved, the appellate court reviews for harmless error — requiring the state to prove beyond a reasonable doubt that the error had no effect on the verdict or sentence — and when an issue is not preserved, the appellate court reviews for fundamental error —

Structural errors are those that “affect the entire conduct of the trial from beginning to end, and thus taint the framework within which the trial proceeds.” ¶ 12 (2005) (citations and internal quotations marks omitted).

¶ 19 (2005); STATE v. MULLET Decision of the Court ¶25 Pursuant to Arizona Rule of Evidence 609(a), a party may attack a witness’s character for truthfulness with pr

¶ 22 (2005); (holding that an objection on one ground does not preserve an issue on another ground).

To prevail on fundamental error review, Berliew must “establish both that fundamental error exists and that the error in [her] case caused [her] prejudice.” ¶ 20 (2005).