State v. Ahrens, 1 CA-CR 24-0161

Todd Ervin Ahrens was convicted of transporting methamphetamine for sale after being found in a vehicle with Cynthia Sosa, who possessed two pounds of the drug.
Ahrens and Sosa had traveled from New Mexico to Arizona; the methamphetamine was found in Sosa's bag, and drug paraphernalia was found with Ahrens' belongings.
Ahrens argued he was only present for the ride and not involved in the drug transport, while Sosa testified that Ahrens knew about the meth but denied he was involved in its procurement.
Sosa had previously traveled with Ahrens to Arizona on drug-related trips, providing him with a "cut" of the drugs upon return to New Mexico.
After being found guilty by jury, Ahrens appealed, arguing insufficient evidence for conviction as an accomplice and error in denying immunity for Sosa to testify about prior trips.

Issue	Ahrens's Argument	State's Argument	Held
Sufficiency of Evidence for Accomplice Liability	Evidence showed only presence, no intent to aid	Sufficient evidence Ahrens intentionally aided Sosa	Sufficient evidence; conviction affirmed
Denial of Immunity for Sosa's Testimony	Prevented complete defense; would have rebutted prior trips' impact	No sufficient offer of proof; Sosa's testimony not clearly exculpatory	No error; no prejudice shown
Rule 20 Motion for Acquittal	Insufficient evidence to go to jury	Jury could infer knowledge/intent from evidence	Motion properly denied
New Trial Based on Weight of Evidence	Verdict was against weight of evidence	Evidence sufficient under legal standard	Motion for new trial properly denied

State v. Teagle, 217 Ariz. 17 (elements of constructive possession and accomplice liability)
State v. Barreras, 112 Ariz. 421 (constructive possession may be shown by dominion and control)
State v. Haas, 138 Ariz. 413 (deliberate ignorance can satisfy knowledge requirement for accomplice liability)
State v. Axley, 132 Ariz. 383 (immunity for witness only where testimony is clearly exculpatory and essential)