State of Arizona v. Douglas Lee Eddington, 266 P.3d 1057

Arizona Supreme Court, en banc, affirmed the Court of Appeals’ disposition on whether a peace officer employed by the investigating agency is disqualified from juror service under A.R.S. § 21-211(2).
Douglas L. Eddington was charged as an accomplice in the murder of a Tucson police officer’s son; voir dire revealed a deputy sheriff employed by the investigating agency was on the panel and knew many witnesses.
The trial court denied Eddington’s for-cause strike; Eddington used a peremptory strike to remove the deputy; the jury convicted Eddington of second-degree murder.
The Court of Appeals concluded peace officers employed by the investigating agency are “interested persons” under § 21-211(2) and disqualified; it affirmed the conviction.
The Arizona Supreme Court granted review to resolve statewide importance of § 21-211(2)’s application in this context; it affirms the Court of Appeals.
The Court emphasizes the interests and appearance of fairness, and holds that the deputy was disqualified irrespective of his asserted ability to be fair.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a peace officer employed by the investigating agency is an “interested person” under § 21-211(2).	State—peace officer employed by investigating agency is an interested person and disqualified.	Eddington—argues officer’s employment does not automatically disqualify if he can be fair.	Yes; such an officer is disqualified.
Does § 21-211(2) aim to maintain appearance of fairness and restrict juror influence regardless of actual impartiality?	State—appearance of fairness supports disqualification.	Eddington—asserts actual impartiality may render disqualification unnecessary.	The appearance and interest concerns support disqualification.

Lopez v. Farmers Ins. Co., 177 Ariz. 371 (App. 1993) (interested due to possible effect on premiums (insurer as party))
Salt River Valley Water Users’ Ass’n v. Berry, 31 Ariz. 39 (1926) (interest extends beyond pecuniary to loyalties or alignment)
Carpenter v. Superior Court, 176 Ariz. 486 (App. 1993) (investigating agency acts as part of prosecution)
State v. Williams, 183 Ariz. 368 (1995) (investigating agency’s role and disclosure obligations)
Hill, 174 Ariz. 313 (1993) (police officers not automatically disqualified; context matters)
Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984) (appearance of fairness and public confidence in judiciary)
Irvin v. Dowd, 366 U.S. 717 (1961) (fair trial requires unbiased jurors)
Miller, 178 Ariz. 555 (1994) (jury impartiality and fairness considerations)