State v. Alexander, 1 CA-CR 15-0683

Police observed suspected hand-to-hand drug activity outside motel rooms 240–241; motel management asked police to remove occupants.
Officer Linker approached room 241, found Defendant David Lee Alexander standing half-inside the doorway, asked to enter, and testified Defendant consented.
Inside, Officer Linker asked questions and obtained Defendant’s consent to search; he found a marijuana pipe, methamphetamine and crack paraphernalia, bags of methamphetamine and cocaine, and pills later identified as Oxycodone and Alprazolam.
Defendant admitted ownership of the items and said he sold drugs to make money.
Defendant was charged with multiple counts including possession for sale; the jury convicted him of possession and paraphernalia offenses and lesser-included possession counts; the court imposed concurrent presumptive prison terms (longest 10 years).
On appeal, Alexander argued (1) the trial court erred in denying his motion to suppress the warrantless entry/search, and (2) the court erred by allowing impeachment with an unsanitized prior felony conviction after he testified.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether entry/search of motel room was consensual	State: Officer Linker credibly testified Alexander consented to entry and to successive searches; State bears preponderance to show consent	Alexander: He never gave consent; officer's equivocal reports and testimony insufficient to prove consent	Court: No clear error — record supports that Alexander consented; denial of suppression affirmed
Whether trial court erred in allowing impeachment with unsanitized prior felony	State: After defendant denied being a drug dealer, his testimony opened the door to impeachment with the 2006 drug-sale conviction (probative of truthfulness)	Alexander: His brief denial did not violate the court's admonition; unsanitized conviction should remain excluded	Court: No abuse of discretion — defendant "opened the door"; court properly allowed impeachment and cautioned jury; verdicts support no undue prejudice

Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (consent exception to the warrant requirement and voluntariness standard)
State v. Valenzuela, 239 Ariz. 299 (2016) (State must prove consent by preponderance)
State v. Newell, 212 Ariz. 389 (2006) (standard of review on suppression rulings and juror instruction presumption)
State v. Martinez, 127 Ariz. 444 (1980) (previously excluded evidence may be admitted if defendant opens the door)
State v. Canez, 202 Ariz. 133 (2002) (prior Arizona authority regarding consent standard, abrogated by rule change)
Scott v. United States, 436 U.S. 128 (1978) (Fourth Amendment protects against unreasonable searches and seizures)