State of Arizona v. Samkeita Jahveh Jurden, 239 Ariz. 526

In Sept. 2012 Jurden refused to leave a department store; officers attempted to arrest him and he resisted (biting/kicking one officer and flailing away from another) during a single, uninterrupted ~4-minute struggle.
A grand jury indicted Jurden on two counts of resisting arrest under A.R.S. § 13-2508(A)(1) — one for each officer — plus assault and trespass counts; a jury convicted on all but one aggravated-assault count.
The trial court imposed concurrent sentences and explained the resistance was “one incident” without meaningful break.
On appeal a divided court of appeals vacated one resisting-arrest conviction as violating double jeopardy; the State sought review.
The Arizona Supreme Court considered whether § 13-2508 permits multiple convictions for a single, continuous course of resistance involving multiple officers, and whether multiple convictions here violate the Double Jeopardy Clause.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jurden)	Held
Whether § 13‑2508 permits multiple convictions when a single continuous act of resistance involves multiple officers	Statute is victim-directed: each officer resisted is a separate offense	Statute is event-directed: single continuous resistance is one offense regardless of number of officers	Held: event-directed; only one conviction allowed for a single, uninterrupted course of resisting an arrest
Whether multiple convictions here violate the Double Jeopardy Clause	Multiple convictions are permissible because separate officers were targeted	Multiple convictions punish the same offense twice, violating double jeopardy	Held: multiple convictions for one continuous resistance violate double jeopardy; vacated the second resisting-arrest conviction
Proper unit of prosecution analysis for § 13‑2508	Focus on each officer as unit of prosecution	Focus on each arrest/event as unit of prosecution	Held: unit of prosecution is the event (each uninterrupted course of resisting an arrest)
Whether statutory text, purpose, or context favors victim- or event-directed reading	Text could be read victim-directed; State emphasizes officer protection	Jurden emphasizes statute protects state authority and targets the event of resisting an arrest	Held: statute ambiguous; secondary tools (purpose, structure, placement, rule of lenity) favor event-directed interpretation

Lubin v. Thomas, 213 Ariz. 496 (statutory interpretation reviewed de novo)
Blockburger v. United States, 284 U.S. 299 (test for separate statutory offenses)
Ladner v. United States, 358 U.S. 169 (unit‑of‑prosecution analysis; policy of lenity where ambiguous)
United States v. Universal C.I.T. Credit Corp., 344 U.S. 218 (allowable unit of prosecution concept)
Whalen v. United States, 445 U.S. 684 (Double Jeopardy Clause context)
State v. Jurden, 237 Ariz. 423 (Ct. App. decision vacated; prior appellate holding)
State v. Mitchell, 204 Ariz. 216 (interpretation of "effecting an arrest")
State v. Eagle, 196 Ariz. 188 (Arizona double jeopardy principles)