State of Arizona v. Trent Christopher Benson
232 Ariz. 452
| Ariz. | 2013Background
- Benson was convicted on two counts of first-degree murder and multiple related felonies with a death sentence imposed for each murder.
- He committed crimes against four women over a three-year span: Alisa (2004), Yolanda (2007), Karen (2007), and Melissa (2007).
- DNA from Yolanda’s breast and an upgraded anal swab matched Benson; police later arrested him in spring 2008 after a DNA profile linked all four victims.
- Benson confessed to killing Alisa and Karen and to assaulting Melissa; he denied Yolanda’s assault, offering an alternate explanation for his DNA on Yolanda.
- A jury found Benson guilty on all counts except the Karen sexual assault (returned as attempted sexual assault); three aggravating circumstances were found for each murder, and the court sentenced him to death for both murders plus lengthy non-capital terms.
- Pretrial rulings included denial of motions to sever counts 4 and 5, denial of a suppression motion for a replicate DNA test, and denial of access to DPS partial-matching profiles; at trial, he was restrained with a stun belt and leg brace.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Severance of Yolanda counts from others | Benson | Benson | Court did not abuse discretion; cross-admissible Rule 404 evidence supported joinder. |
| DNA replicate test admissibility | State | Benson | Court did not abuse discretion; non-Frye admissibility under Rules 403/702/703; jury to decide explanations. |
| Disclosures of DPS partial profiles | State | Benson | No Brady violation; information not exculpatory or material given uncertainties. |
| Use of restraints during trial | State | Benson | Court acted within discretion; restraints were non-visible and justified by safety concerns. |
| Parole eligibility in penalty phase | State | Benson | Court properly refused Simmons instruction; Arizona law does not confer a right to parole eligibility. |
Key Cases Cited
- State v. Lehr (Lehr III), 227 Ariz. 140 (Arizona Supreme Court 2011) (rule allowing remote but probative other-act evidence under Rule 404(c))
- State v. Bocharski (Bocharski II), 218 Ariz. 476 (Arizona Supreme Court 2008) (gratuitous violence standard in F(6) aggravator)
- State v. Wallace (Wallace IV), 229 Ariz. 155 (Arizona Supreme Court 2012) (gratuitous violence standard and narrowed mental-state inquiry)
- State v. Gretzler (Gretzler III), 135 Ariz. 42 (Arizona Supreme Court 1983) (framework for heinous, cruel or depraved aggravator)
- State v. Cruz, 218 Ariz. 149 (Arizona Court of Appeals 2008) (court discretion on restraints and security policies)
- State v. Chappell, 225 Ariz. 229 (Arizona Supreme Court 2010) (evidentiary rulings on death-penalty mitigation and standard)