State v. Chandler, 418 P.3d 1109

In Oct. 2015, Robert Chandler placed a hidden camera in a bathroom and recorded his teenage daughters using the toilet, bathing, and shaving their genitals.
One daughter discovered the camera, removed its memory card, and law enforcement was notified; the card was corrupted but videos were found on Chandler's computer.
Chandler was tried and convicted on three counts of sexual exploitation of a minor and received enhanced consecutive prison terms totaling 26.25 years plus lifetime probation.
At the close of evidence Chandler moved for judgment of acquittal under Rule 20, arguing the evidence was insufficient because the statute requires the minor to be engaged in "sexual conduct."
The trial court denied the Rule 20 motion; on appeal Chandler challenged the statutory interpretation of "exploitive exhibition or other sexual conduct" and the phrase "for the purpose of sexual stimulation of the viewer."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sexual-exploitation statute requires the minor to be engaged in sexual conduct (i.e., intent/act by the minor)	State: statute covers recording a minor engaged in exploitive exhibition or other sexual conduct	Chandler: statute requires the minor themself to be acting with sexual intent; Gates required minor's intent	Held: statute does not require the minor to intend sexual stimulation; focuses on defendant/viewer intent
Meaning of "exploitive exhibition" and "for the purpose of sexual stimulation of the viewer"	State: phrase targets subject (photographer/viewer) intent to sexually stimulate	Chandler: phrase means the minor must act to sexually stimulate the viewer	Held: "for the purpose of sexual stimulation of the viewer" refers to viewer/photographer's purpose, not the minor's intent
Whether the legislature intended to change preexisting Gates precedent	Chandler: relies on Gates' focus on minor's lewd exhibition	State: legislative amendments and history changed Gates' result	Held: legislative amendments and committee materials show intent to change Gates; statute covers non-lewd but exploitive recordings
Whether application here risked criminalizing innocent nude images	Chandler: concern that broad reading could punish innocent nudity	State: conviction supported by evidence of sexual purpose (Chandler admitted sexual arousal)	Held: statute still requires proof of photographer's sexual purpose; no error applying statute here

State v. Gates, 182 Ariz. 459 (1994) (prior interpretation requiring minors be engaged in lewd exhibition)
State v. West, 226 Ariz. 559 (2011) (sufficiency of the evidence reviewed de novo)
State v. Skiba, 199 Ariz. 539 (2001) (statutory interpretation reviewed de novo)
State v. Pledger, 236 Ariz. 469 (2015) (plain-language statutory interpretation)
State v. Givens, 206 Ariz. 186 (2003) (use of context and legislative history when statutes ambiguous)
Zamora v. Reinstein, 185 Ariz. 272 (1996) (factors for resolving statutory ambiguity)
State v. Pennington, 149 Ariz. 167 (1985) (presumption legislature is aware of existing case law)
State v. Fell, 209 Ariz. 77 (2004) (presumption that legislative amendments change existing law)
State v. Eminowicz, 21 Ariz. App. 417 (1974) (policy determinations belong to legislature)
State v. Gagnon, 236 Ariz. 334 (2014) (prosecutorial discretion to choose applicable statute)