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An error is harmless if this Court can determine, beyond a reasonable doubt, that the error “did not contribute to or affect the verdict.”

(“The focus is on the fairness of the trial, not the culpability of the prosecutor.”); Smith v. Phillips, 455 U.S. 209, 219 (1982) (“Past decisions of this Court demonstrate that the touchstone of due process analysis in cases of alleged prosecutorial misconduct is the fairness of the trial, not the culpab

is harmless if we can say, beyond a reasonable doubt, that the error did not contribute to or affect the verdict.”

"We review a denial of a Rule 20 motion de novo, 'viewing the evidence in a light most favorable to sustaining the verdict.'" ¶ 69 (2022) ().

See Martinez, 196 Ariz. at 459, ¶ 28 (“If a juror is willing to put aside his opinions and base his decision solely upon the evidence, he may serve.”); (concluding that no fundamental error occurred when the superior court did not sua sponte strike jurors who indicated that “they would find it difficult but not impossible to be fair and impartial”).

“When an issue is raised but erroneously ruled on by the trial court, this court reviews for harmless error.”

¶ 32 (2018); (The court’s refusal to strike jurors who believed it would be difficult but not impossible for them to be impartial was not error.), abrogation on other grounds recognized by McKinney v. Ryan, 813 F.3d 798, 815 (9th Cir. 2015).

-89 (1993) (The erroneous admission of DNA probability calculations was harmless because the properly admitted evidence went “far beyond overwhelming evidence of [the defendant’s] guilt” of murder, “refut[ing] any hypothesis other than [his] guilt” and “point[ing] with unerring consistency to one inarguable conclu

(“[D]uring closing arguments counsel may summarize the evidence.”).

(holding that even if a “comment during opening statement was improper at that point, it was a reasonable inference from evidence later introduced and would have been proper during closing argument,” so the defendant was not deprived of a fair trial), abrogated in part on other grounds as recognized in McK

(“Only fundamental error .

The burden to show prejudice is on the defendant, Payne, 233 Ariz. at 499 ¶ 28, and is “extremely heavy,” Forde, 233 Ariz. at 554 ¶ 13 ().

6 STATE v. WILLIAMS Decision of the Court for the evidence which is to be heard,” and closing argument to “summarize the evidence, make submittals to the jury, urge the jury to draw reasonable inferences from the evidence, and suggest ultimate conclusions,”

In State v. Bible, our supreme court held that the court’s failure to strike jurors who would “find it difficult” to be objective was not fundamental error because the jurors said they could “sit fairly and impartially and base their verdict solely on the evidence presented.”

(looking to whether improper statement “tipped the scales of justice and denied Defendant a fair trial”).

(preserved error reviewed for harmlessness)

In considering this question, we examine “the error in light of all of the evidence.”

(once defendant has shown error, burden shifts to state to prove error harmless); (state has burden of convincing appellate court that “guilty verdict actually rendered in this trial was surely unattributable to the error” ()).

the victim’s rights must yield.”); (“It cannot be doubted that victims of crime, and their families, have certain rights.