State of Arizona v. Andre Michael Leteve, 237 Ariz. 516

Background

In March 2010 Andre Michael Leteve killed his two young sons and shot himself; he called 911 and left notes to his estranged wife; police found both children shot to death.
A jury convicted Leteve of two counts of first‑degree murder and found three aggravators: (F)(6) heinous/cruel/depraved, (F)(8) multiple homicides, (F)(9) victims under 15; the jury imposed death sentences for each count.
Pretrial and trial issues included (1) admission of Leteve’s custodial statements made before Miranda warnings, (2) admission of numerous other‑acts (Rule 404(b)) evidence about retaliatory conduct toward his wife, (3) exclusion/limitation of mental‑health observation testimony and prescription‑drug evidence, and (4) admission of non‑family impact testimony and other penalty‑phase evidentiary rulings.
The trial court admitted most statements under the public‑safety (Quarles) exception and admitted other‑acts evidence for motive/intent; it limited expert and some family observation testimony and excluded certain prescription evidence without defendant’s testimony.
On appeal the Arizona Supreme Court reviewed those evidentiary rulings, the (F)(6) jury instruction, penalty‑phase evidence, restitution, and whether any errors were harmless beyond a reasonable doubt.

Issues

Issue	State's Argument	Leteve's Argument	Held
Admissibility of pre‑Miranda statements at scene	Statements were elicited to secure officer/public safety and identify victims/locations; Quarles exception applies	Statements were inadmissible because they were made in custody before Miranda warnings	Admitted under Quarles except for one purely testimonial answer; court affirms admission as not an abuse of discretion
Admission of other‑acts (404(b)) evidence	Acts showing long‑running retaliation against wife probative of motive/intent and plan; probative value not outweighed by prejudice	Improper propensity evidence because wife was not the murder victim	Evidence admissible for motive/intent; trial court did not abuse discretion and gave limiting instruction
Exclusion/limitation of mental‑health observation and prescription‑drug evidence	Court acted within rules; some limits warranted	Excluding expert observation testimony and barring prescription evidence (unless defendant testified) prevented rebuttal of premeditation and forced self‑incrimination	Court found exclusion of expert observation and prescription evidence erroneous but harmless beyond a reasonable doubt given overwhelming evidence of premeditation
Admission of non‑family neighborhood impact rebuttal testimony	Rebuttal evidence of specific harm to community members is relevant to rebut mitigation and allowed if not unduly prejudicial	Testimony about neighbors’ emotional harm was improper victim‑impact or unduly prejudicial; mistrial warranted	Testimony admissible as limited rebuttal; not so prejudicial as to require mistrial, but courts should limit such non‑family impact testimony prospectively

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warning requirement for custodial interrogation)
New York v. Quarles, 467 U.S. 649 (U.S. 1984) (public‑safety exception to Miranda)
Clark v. Arizona, 548 U.S. 735 (U.S. 2006) (distinguishing observation evidence from mental‑disease or capacity evidence)
State v. Christensen, 129 Ariz. 32 (Ariz. 1981) (admitting behavioral observation evidence to show reflexive tendencies)
State v. Gretzler, 135 Ariz. 42 (Ariz. 1983) (factors for heinous or depraved aggravator)
State v. Stanley, 167 Ariz. 519 (Ariz. 1991) (senselessness and helplessness factors applied to child victims)
State v. Milke, 177 Ariz. 118 (Ariz. 1993) (use of parent–child relationship in heinousness analysis)
Payne v. Tennessee, 501 U.S. 808 (U.S. 1991) (victim‑impact evidence relevance in sentencing)
Sullivan v. Louisiana, 508 U.S. 275 (U.S. 1993) (harmless‑beyond‑reasonable‑doubt standard for constitutional errors)
State v. Villalobos, 225 Ariz. 74 (Ariz. 2010) (limiting instruction and admissibility standards for penalty‑phase evidence)