State v. Abdi, 248 P.3d 209

Abdi and his girlfriend stayed in L.'s one-bedroom apartment for about four weeks; L. asked them to move out.
After moving out, Abdi returned, banged on the door and threatened to shoot; L. kept the door locked and Abdi left.
A few days later, Abdi returned at midnight; L. tried to close and lock the door, but Abdi forced entry and a struggle ensued.
During the struggle, Abdi pulled a knife and stabbed L. multiple times; Abdi fled and L. called the police.
Abdi was arrested and charged with aggravated assault; a jury convicted him and the trial court sentenced him to 9.5 years' imprisonment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 13-419 residence-presumption instruction was error	Abdi argues the instruction created a mandatory presumption favoring the victim.	State argues the instruction tracks the statute and applies to a defendant’s justification defense in context.	Reversed; instruction created a mandatory presumption and shifted burden.
Effect of the production-of-evidence instruction	Abdi contends it suggested the state need not prove all elements.	State contends the instruction, read with others, confirms proof beyond a reasonable doubt.	No error; instruction read in context did not mislead.
Evidentiary ruling on immigration status cross-examination	Abdi claims immigration status evidence would show motive to accuse.	State argues cross-examined immigration status is collateral and cumulative.	No abuse of discretion; exclusion within trial court's wide discretion.
Exclusion of torture testimony about Abdi's childhood	Absent testimony to explain fear and flight, defense is incomplete.	Testimony would be irrelevant or unduly prejudicial and cumulative.	No reversible error; court did not abuse discretion; no fundamental error.

State v. Anderson, 210 Ariz. 327 (2005) (abuse-of-discretion standard for jury instructions)
State v. Orendain, 188 Ariz. 54 (1997) (whether instruction accurately states law)
State v. Gallegos, 178 Ariz. 1 (1994) (instructions viewed as a whole)
State v. Lopez, 134 Ariz. 469 (App. 1982) (mandatory vs permissive presumptions)
State v. Grilz, 136 Ariz. 450 (1983) (interpretation of presumptions in jury instructions)
Francis v. Franklin, 471 U.S. 307 (1985) (constitutional concerns regarding mandatory presumptions)
Sandstrom v. Montana, 442 U.S. 510 (1979) (mandatory presumption analysis)
State v. Platt, 130 Ariz. 570 (App. 1981) (burden-shifting presumptions and due process)
State v. King, 225 Ariz. 87 (2010) (state must prove lack of justification when self-defense is raised)
State v. Henderson, 210 Ariz. 561 (2005) (fundamental-error review for due process claims)
State v. Herrera, 203 Ariz. 131 (App. 2002) (cross-examination limits and collateral matters)
State v. Cañez, 202 Ariz. 133 (2002) (limits on cross-examination; confrontation considerations)
State v. Bracy, 145 Ariz. 520 (1985) (evidence admissibility balancing considerations)