State v. Ali, 1 CA-CR 16-0502

Early-morning traffic stop for a broken headlight; officer discovered Ali’s license was suspended and called for backup.
Officers attempted to arrest Ali; she initially placed her hands behind her back but struggled while an officer tried to handcuff her other wrist; she flailed, yelled profanities and racial epithets.
After being handcuffed, Ali sat with one leg outside the patrol vehicle, kicked an officer in the mid-thigh with her heel, and continued to resist; officers secured her in a restraint “wrap” and transported her to jail.
A jury convicted Ali of aggravated assault (Class 5 felony), resisting arrest (Class 6 felony charged but later designated a Class 1 misdemeanor at sentencing), and driving on a suspended license (Class 1 misdemeanor).
The superior court imposed concurrent probationary terms (greater term two years) and one day incarceration (with one day credit); Ali timely appealed under Anders/Leon procedures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for convictions	State: direct and circumstantial evidence supported jury verdicts	Ali (via appellate counsel): no nonfrivolous challenge raised; record reviewed for fundamental error	Court: evidence sufficient; affirmed convictions
Jury composition and unanimity	State: jury of eight properly instructed; verdict unanimous	Ali: no specific claim raised	Court: jury properly composed, instructed, verdict unanimous and polled
Trial procedure and fairness	State: appropriate pretrial hearings; counsel and defendant present at critical stages	Ali: no specific claim raised	Court: record shows fair trial; no reversible error
Sentencing/classification of resisting arrest	State: sentencing lawful; court designated resisting arrest as Class 1 misdemeanor	Ali: no challenge raised	Court: imposed legal probationary terms; affirmed sentence

Anders v. California, 386 U.S. 738 (1967) (announcing procedure when appellate counsel finds appeal frivolous)
Smith v. Robbins, 528 U.S. 259 (2000) (procedural standards for counsel’s duties in Anders-type appeals)
State v. Leon, 104 Ariz. 297 (1969) (Arizona authority on counsel’s duty and court’s review when appeal is frivolous)
State v. Clark, 196 Ariz. 530 (App. 1999) (standards for Anders/Leon appellate review in Arizona)
State v. Payne, 233 Ariz. 484 (2013) (instructing that appellate review views facts in light most favorable to sustaining verdict)
State v. Shattuck, 140 Ariz. 582 (1984) (advising counsel’s post-appeal obligations and defendant’s rights to seek review)