State of Arizona Ex Rel. Polk v. Hon. campbell/francis Frederick Kraps, 372 P.3d 929

Francis Kraps was indicted on two counts of child prostitution under A.R.S. § 13-3212(B)(2) based on alleged acts with persons he believed to be 16-year-olds; those persons were undercover peace officers.
The superior court ruled the enhanced sentencing (class 2 felony, mandatory terms, no early release/probation) and consecutive-sentence provisions in § 13-3212(D) and (G) apply only when the victim is an actual minor, not an undercover officer.
The court of appeals reversed, holding the enhancements apply when an undercover officer poses as a 15–17 year old; it did not address consecutive sentencing under (D).
The Arizona Supreme Court granted review to resolve whether the word “minor” in subsections (D) and (G) includes undercover peace officers or their assistants who pose as 15–17 year olds.
The statute already bars the defense that the person was a peace officer posing as a minor (subsection (C)), and the 2010–2011 amendments restructured offenses and penalties by victim age and offender knowledge.
The Supreme Court reversed the trial court, holding subsections (D) and (G) apply when the “minor” is an undercover peace officer or someone assisting a peace officer who is posing as age 15–17.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentencing enhancements and consecutive-sentence requirements in A.R.S. § 13-3212(D) and (G) apply when the person posing as a minor is an undercover peace officer	Kraps: “Minor” means an actual person under 18; enhancements don’t apply to adult officers posing as minors	State: Conviction under (B)(2) is allowed when the other person is an officer posing as a minor (per (C)); thus “minor” in (D) and (G) includes such officers	Court: “Minor” in (D) and (G) includes persons aged 15–17, peace officers posing as 15–17 year olds, and persons assisting such officers; enhancements and consecutive sentences apply

Ariz. Citizens Clean Elections Comm’n v. Brain, 234 Ariz. 322 (2014) (standards for statutory interpretation and de novo review of legal questions)
Baker v. Univ. Physicians Healthcare, 231 Ariz. 379 (2013) (primary objective of statutory interpretation is to effectuate legislative intent)
Deer Valley Unified Sch. Dist. No. 97 v. Houser, 214 Ariz. 293 (2007) (apply unambiguous statutory language as written)
Lewis v. Debord, 238 Ariz. 28 (2015) (courts may not rewrite statutes)
State v. Regenold, 227 Ariz. 224 (2011) (court of appeals held DCACA enhancements did not apply when victim was an undercover officer in a different statute)
State v. Villegas, 227 Ariz. 344 (2011) (court of appeals interpreted luring statute enhancements as applying only when the victim was actually a child)
State v. Williams, 175 Ariz. 98 (1993) (discussing crimes against children as crimes against children qua child)