State v. Bruno, 1 CA-CR 17-0078

Early morning, Jan. 17, 2016: Bruno entered a trailer while Sandra and Jason were sleeping and was armed with a shotgun; Sandra wrestled the gun away and called 911; police arrested Bruno at the scene.
Jason testified the trailer belonged to his mother, was used for sleeping (multiple beds), had a kitchen and bathroom, and Bruno did not have permission to enter that night.
Bruno was indicted on six counts including first-degree burglary (A.R.S. § 13-1508/13-1507) and multiple aggravated-assault counts; two misdemeanor counts were dismissed pretrial.
After the State rested, Bruno moved under Ariz. R. Crim. P. 20 for judgment of acquittal on first-degree burglary; the court denied the motion; the jury convicted on all counts.
Bruno was sentenced to seven years for first-degree burglary (concurrent five-year terms on other felonies) and appealed only the denial of the Rule 20 motion as to count one.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient evidence that Bruno unlawfully entered or remained in the trailer	State: testimony showed Bruno was not authorized to be in the trailer and, if he had prior permission, he exceeded its scope by entering armed while occupants slept	Bruno: insufficient proof he entered or remained unlawfully	Court: Sufficient evidence; Jason’s testimony supported unlawful entry or exceeding permission
Whether the trailer qualified as a “residential structure” under A.R.S. § 13-1501(11)	State: trailer had beds, kitchen, bathroom; occupants slept there—adapted for human residence and lodging	Bruno: relying on State v. Bass, argued lack of plumbing/electricity meant not residential	Court: Sufficient evidence for a jury to find trailer was a residential structure despite Bass distinction

State v. Parker, 231 Ariz. 391 (discussing de novo review and standard for Rule 20 motions)
State v. Bible, 175 Ariz. 549 (de novo review of acquittal motions)
State v. Fulminante, 193 Ariz. 485 (defining substantial evidence standard)
State v. West, 226 Ariz. 559 (definition of substantial evidence)
State v. Johnson, 215 Ariz. 28 (reversal standard for acquittal denials)
State v. Mauro, 159 Ariz. 186 (probative facts requirement for convictions)
State v. Van Dyke, 127 Ariz. 335 (scope of permission can negate an otherwise lawful entry)
State v. Engram, 171 Ariz. 363 (temporary/unfinished dwellings can be residential structures)
State v. Bass, 184 Ariz. 543 (distinguishable; addressed factors like utilities when evaluating residential status)