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State of Arizona v. Miguel Francisco Inzunza
234 Ariz. 78
| Ariz. Ct. App. | 2014
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Background

  • 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)
Read the full case

Case Details

Case Name: State of Arizona v. Miguel Francisco Inzunza
Court Name: Court of Appeals of Arizona
Date Published: Jan 27, 2014
Citation: 234 Ariz. 78
Docket Number: 2 CA-CR 2012-0273
Court Abbreviation: Ariz. Ct. App.