State of Arizona v. Rohan Livingston Butler, 230 Ariz. 465

Butler was convicted of conspiracy to possess or transport marijuana for sale, possession of marijuana for sale, and possession of a deadly weapon during a felony drug offense.
Evidence showed drugs, firearms, ledgers, cash, and shipping materials at two Arizona houses and in Butler’s car during police searches.
One handgun was found in Calle Lado Al Rio; two handguns were found in Camino Laguna Seca; cash and crime-related documents were seized.
A Georgia property receipt linked Butler to cash, suggesting cross-state drug proceeds and conspiracy activity.
Butler challenged the trial court’s rulings on sufficiency of the evidence, a Batson challenge, admissibility of the Georgia receipt, and a duplicitous indictment; the court affirmed.
The court addressed whether the indictment’s single count for three guns was duplicitous and whether Rule 404(b) and Rule 403 concerns were satisfied to admit the Georgia receipt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for weapons charge	Butler argued no proof he possessed weapons	State argued evidence showed knowledge and possession	Evidence supported possession during the felony drug offense
Duplicitous indictment	Indictment grouped three weapons in one count; prejudicial	Indictment was duplicitous; potential prejudice avoided by verdict forms	Court treated as duplicitous indictment but found no prejudice; affirmed verdicts
Admissibility of Georgia property receipt	Receipt is hearsay and prejudicial	Receipt probative to conspiracy and intrinsic evidence	Receipt admitted; not fundamental error; probative value outweighed prejudice
Batson challenge	Strikes of two African-American jurors suggested discrimination	Explanations race-neutral; trial court did not err	Batson challenge denied; strikes race-neutral; conviction affirmed
Law of the case / preclusion of challenge	Francis memorandum decision barred Butler’s Batson merits	Law of the case not controlling for Butler	No law-of-the-case preclusion; Butler may raise Batson merits on appeal

State v. Francis, 224 Ariz. 369 (App. 2010) (Batson challenge addressed in memorandum decision; not published; law-of-the-case issue)
State v. Hargrave, 225 Ariz. 1 (App. 2010) (duplicitous indictment; presumption of prejudice; fundamental error review)
State v. Rushton, 172 Ariz. 454 (App. 1992) (complicity approach for prejudice in duplicity)
State v. Anderson, 210 Ariz. 327 (2005) (pretrial cure for duplicity; notice requirements)
State v. Veatch, 132 Ariz. 394 (1979) (general abuse-of-discretion standard guidance)
State v. Velazquez, 216 Ariz. 300 (App. 2007) (Rule 404(b) analysis; intrinsic vs non-propensity)