State of Arizona v. Miguel Francisco Inzunza
234 Ariz. 78
| Ariz. Ct. App. | 2014Background
- Victim, a 26-year-old with significant intellectual disability, was left unsupervised; she was found with Inzunza asleep next to her in his apartment after police entered following a missing-person report.
- DNA evidence showed Inzunza’s DNA on the victim’s breast and the victim’s DNA on Inzunza’s penis, supporting sexual contact.
- Jury convicted Inzunza of two counts of sexual abuse; the sexual assault count was hung as a mistrial, with sexual abuse as a lesser-included offense charged.
- Inzunza was sentenced to consecutive prison terms enhanced by a Washington out-of-state felony conviction; a separate criminal restitution order was imposed, later to be vacated.
- The trial court denied suppression of the warrantless entry under the emergency-aid rationale; the court later excluded prior unrelated sexual-assault evidence under Rule 403.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrantless entry was lawful under emergency-aid exception | State | Inzunza | No abuse of discretion; entry justified |
| Whether prior unrelated sexual-assault evidence was admissible | State | Inzunza | Precluded under Rule 403; not clearly helpful to show capacity to consent |
| Whether Washington conviction qualifies as a historical prior felony | State | Inzunza | Washington conviction valid as historical prior felony under statute |
| Whether the criminal restitution order was properly imposed | State | Inzunza | CRO improperly imposed; vacated; remainder affirmed |
Key Cases Cited
- State v. Butler, 232 Ariz. 84 (2013) (standard for suppression review; appellate abuse of discretion review)
- State v. Fisher, 141 Ariz. 227 (1984) (emergency aid exception to warrantless searches)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (Fourth Amendment; objective reasonableness in emergency entry)
- State v. Moran, 232 Ariz. 528 (App. 2013) (historical-prior-conviction element-based analysis)
- Crawford v. Moran, 214 Ariz. 129 (2007) (out-of-state convictions in repetitive-offender context)
