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The statement asking the jury to do “justice for Edgar” was arguably inappropriate insofar as it asked the jury to “strike some sort of balance between the victim’s and the defendant’s rights.” (stating that asking the jury to strike such a balance is improper).

See Henderson, 210 Ariz. at 567 ¶ 20 (equating prejudice with an unfair trial) (citing Hunter, 142 Ariz. at 90 (holding that defendant must prove fundamental error exists, and is of such magnitude that he could not have received a fair trial)); (“A fair trial is a fundamental liberty secured by the United States and Arizona Constitutions.” (citing Ariz. Const. art. 2, §§ 4, 24)).

“This deferential standard of review applies because the trial judge is in the best position to evaluate ‘the atmosphere of the trial, the manner in which the objectionable statement was made, and the possible effect it had on the jury and the trial.’” ().

¶12 Courts "rarely presume prejudice due to outrageous pretrial publicity," State v. Bible , , 564, , 1167 (1993), because of the defendant's extremely heavy burden to show "the publicity [is] 'so unfair, so prejudicial, and so pervasive that [the trial court] cannot give any credibility to the jurors' answers during voir dire,' " Cruz , 218 Ariz. at 157 ¶ 15, 181 P.3d at 204 (quoting State v. B

(concluding that no fundamental error occurred when the trial court did not sua sponte strike several jurors who “indicated that, for one reason or another, they would find it difficult but not impossible to be fair and impartial”).

See State v. Bible , , 602-03, , 1205-06 (1993) (the court must balance the victim's rights against those of the defendant if the victim's rights conflict with the defendant's right to a fair trial); see also State ex rel.

(“[W]e are not bound by the United States Supreme Court’s non-constitutional construction of the Federal Rules of Evidence when we construe the Arizona Rules of Evidence.”).

(“[D]uring closing arguments counsel may summarize the evidence, make submittals to the jury, urge the jury to draw reasonable inferences from the evidence, and suggest ultimate conclusions.”).

¶ 15 (2011) (noting that sufficiency of the evidence presents a question of law reviewed de novo) ().

“Fundamental error is error going to the foundation of the case, error that takes from the defendant a right essential to his defense, and error of such magnitude that the defendant could not possibly have received a fair trial.” (quotation omitted); (“To qualify as ‘fundamental error,’ .

Here, the prosecutor was “urg[ing] the jury to draw reasonable inferences from the evidence.”

(“We conduct a de novo review of the trial court’s decision” of whether to grant a motion for acquittal.).

(“Error, be it constitutional or otherwise, is harmless if we can say, beyond a reasonable doubt, that the error did not and arrested Appellant, despite protestations by the other occupants of Apartment 13 that Brown was the person who had attacked the victims.

(“Error, be it constitutional or otherwise, is harmless if we can say, beyond a reasonable doubt, that the error did not contribute to or affect the verdict.”); ¶ 44 (2003) (“Although evidence of prior crimes generally is not admissible, courts will not reverse a conv