Cited by
Opinions in Arizona that cite State v. Lehr, 254 P.3d 379.
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State v. Gomez
Ariz. Ct. App. Div. 1 2026
More recently, our Supreme Court noted that “voluntariness is ultimately a legal question” and explained that “[w]e review de novo whether a defendant knowingly and voluntarily waived his right to be present at trial.” ¶ 8 (2011); ¶ 23 (2013) (quoting Lehr).
- State v. Gastelum Ariz. Ct. App. Div. 1 2026
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State v. Gastelum
Ariz. Ct. App. Div. 1 2026
“Even a single partial juror violates a defendant’s constitutional right to a fair trial.” ¶ 49 (2011) (quotation omitted).
- Lopez v. State Ariz. Ct. App. Div. 1 2025
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Lopez v. State
Ariz. Ct. App. Div. 1 2025
Under the Due Process Clause, a criminal defendant is entitled to a “meaningful opportunity to present a complete defense.” California v. Trombetta, 467 U.S. 479, 485 (1984); ¶ 39 (2011); U.S. Const. amend.
- State v. Zweifelhofer Ariz. Ct. App. Div. 1 2025
- State v. Zweifelhofer Ariz. Ct. App. Div. 1 2025
- State v. Swift Hawk Ariz. Ct. App. Div. 1 2024
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State v. Swift Hawk
Ariz. Ct. App. Div. 1 2024
See Williams, 144 Ariz. at 442; ¶¶ 69–70 (2011) (finding the state's procedural error did not prejudice the defendant because the defendant "had notice of the prior convictions the State intended to use as aggravating circumstances").
- State v. Leonard Ariz. Ct. App. Div. 1 2024
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State v. Leonard
Ariz. Ct. App. Div. 1 2024
¶ 39 (2011) (“The Due Process Clause of the Fourteenth Amendment requires that ‘criminal defendants be afforded a meaningful opportunity to present a complete defense.’”) (quoting California v. Trombetta, 467 U.S. 479, 485 (1984)).
- State v. Faria Ariz. Ct. App. Div. 1 2024
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State v. Faria
Ariz. Ct. App. Div. 1 2024
¶ 19 (2011) (prior bad acts); ¶ 10 (App. 2015) (motion to suppress).
- State v. Brown 556 P.3d 776 Ariz. Ct. App. Div. 1 2024
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State v. Brown
556 P.3d 776
Ariz. Ct. App. Div. 1 2024
¶ 51 (2011) ( ¶ 27 (2009)).
- State v. Osborne Ariz. Ct. App. Div. 1 2023
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State v. Osborne
Ariz. Ct. App. Div. 1 2023
The court, however, need not find that the other acts are “perfectly similar in order for evidence of them to be admitted under Rule 404.” 6 STATE v. OSBORNE Decision of the Court ¶ 21 (2011).
- State v. Lohmeier Ariz. Ct. App. Div. 1 2023
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State v. Lohmeier
Ariz. Ct. App. Div. 1 2023
¶18 The failure to preserve potentially useful evidence, on the other hand, “does not constitute a denial of due process of law unless the defendant can show bad faith on the part of the police.” ¶ 41 (2011) (quotation omitted).
- State v. James Ariz. Ct. App. Div. 1 2021
- State v. James Ariz. Ct. App. Div. 1 2021
- State v. Wade Ariz. Ct. App. Div. 1 2021
- State v. Wade Ariz. Ct. App. Div. 1 2021
- State v. Cuevas Ariz. Ct. App. Div. 1 2020
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State v. Cuevas
Ariz. Ct. App. Div. 1 2020
“Acts need not be perfectly similar in order for evidence of them to be admitted under Rule 404[c].” ¶ 21 (2011) (concluding, inter alia, that other act evidence with “extensive similarities” were admissible despite other differences in circumstance, including varied age of victims, involved in such acts).
- State v. Hamilton Ariz. Ct. App. Div. 1 2020
- State v. MacIas 469 P.3d 472 Ariz. Ct. App. Div. 1 2020
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State v. Hamilton
Ariz. Ct. App. Div. 1 2020
But acts “need not be perfectly similar in order for evidence of them to be admitted under Rule 404.” ¶ 21 (2011).
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State v. MacIas
469 P.3d 472
Ariz. Ct. App. Div. 1 2020
P. 32.1(a) (conviction obtained in violation of United States or Arizona Constitution); ¶ 115 (2009) (“[J]uror misconduct warrants a new trial [only] if the defense shows actual prejudice or if prejudice may be fairly presumed from the facts.” (alteration in original) ()); ¶ 49 (2011).
- State v. Campbell Ariz. Ct. App. Div. 1 2020
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State v. Campbell
Ariz. Ct. App. Div. 1 2020
¶20 The collateral estoppel component of double jeopardy does not prohibit the State “from relitigating an issue when it is presented in a subsequent action governed by a lower standard of proof.” Dowling v. United States, 493 U.S. 342, 349 (1990); ¶ 26 (2011) (“[A]dmission of evidence of other acts for which a defendant has been acquitted does not violate double jeopardy.”).
- State v. Sutherland Ariz. Ct. App. Div. 1 2020
- State v. Sutherland Ariz. Ct. App. Div. 1 2020
- State v. Runnels Ariz. Ct. App. Div. 1 2019
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State v. Runnels
Ariz. Ct. App. Div. 1 2019
¶ 24 (2011) (finding harmless error when court failed to give a limiting instruction, focusing on State’s closing urging the jury to consider the evidence only for its proper purpose).
- State v. Hanley Ariz. Ct. App. Div. 1 2018
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State v. Hanley
Ariz. Ct. App. Div. 1 2018
See, ¶ 21 (2011) (noting “[a]cts need not be perfectly similar in order for evidence of them to be admitted under Rule 404.”); ¶ 15 (2011) (noting similarities of victims; that “[i]n each case, a knife was used, the victim was restrained, and homicide was either threatened or occurre
- State v. Ponce Ariz. Ct. App. Div. 1 2018
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State v. Ponce
Ariz. Ct. App. Div. 1 2018
¶22 A defendant has a due process right to have “a meaningful opportunity to present a complete defense.” ¶ 39 (2011).
- State v. Ramos-Ramirez Ariz. Ct. App. Div. 1 2018
- State v. Ramos-Ramirez Ariz. Ct. App. Div. 1 2018
- State v. Wooten Ariz. Ct. App. Div. 1 2018
- State v. Wooten Ariz. Ct. App. Div. 1 2018
- State v. Stoneham Ariz. Ct. App. Div. 1 2017
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State v. Stoneham
Ariz. Ct. App. Div. 1 2017
so 2 McCormick on Evidence § 253 at 248 (Kenneth S. Broun, ed., 7th ed. 2013) ("Under the influence of the Confrontation Clause, a 6 STATE v. STONEHAM Decision of the Court higher standard of disability may be required in criminal cases for witnesses testifying against the accused."); ¶ 33 (2011) (citing Crawford, 541 U.S. at 68) ("The Confrontation Clause allows the admission of testimonial hearsay that satisfies the common law requirements of 'unavailability and a prior opportunity for cross-
- State v. Francisco Ariz. Ct. App. Div. 1 2017
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State v. Francisco
Ariz. Ct. App. Div. 1 2017
–54 (2011) (analyzing an amendment to a notice of aggravators under 13.5(a) and 13.5(b) when the time requirement under Rule 16.1(b) had not been met, the amendment would only be allowed if it was technical or to correct mistakes of fact).
- State v. Mueller Ariz. Ct. App. Div. 1 2017
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State v. Mueller
Ariz. Ct. App. Div. 1 2017
Mueller has a due process right to have “’a meaningful opportunity to present a complete defense,’” ¶ 39 (2011) (quoting California v. Trombetta, 467 U.S. 479, 485 (1984)), including to testify on her own behalf if she elects to do so, Rock v. Arkansas, 483 U.S. 44, 52 (1987); see also Ariz. Const. art 2, § 24
- State v. Vallejos Ariz. Ct. App. Div. 1 2016