State v. Eaton, 1 CA-CR 16-0799

Early morning incident: Eaton played loud music in a fast-food restaurant, refused to turn it down, then pulled a long hunting knife and pointed it at a customer, who feared for his life. Manager called police; Eaton threatened future harm as he left.
Officers located and detained Eaton shortly afterwards; both the victim and manager identified him in separate show-ups. Officers found a long knife in Eaton’s boot. Eaton made statements to police admitting the confrontation and motive (disrespect over music).
Jury convicted Eaton of aggravated assault (class 3 felony); the trial court found four historical out-of-state felony convictions for sentencing and imposed the presumptive 11.25-year term, crediting 289 days.
On appeal Eaton argued: (1) prosecutorial misconduct for comments about plea bargaining in closing argument, and (2) the State failed to prove his four prior convictions with sufficient identification evidence.
The court reviewed the unobjected prosecutor remarks for fundamental error and reviewed the trial court’s finding of prior convictions for abuse of discretion and sufficiency of proof.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Eaton)	Held
Prosecutorial misconduct for referencing plea negotiations in closing	Remarks were permissible commentary explaining why the case went to trial and urging jurors to decide between aggravated assault and disorderly conduct	Remarks improperly suggested Eaton had rejected a plea offer or engaged in plea discussions, violating Rule 410 and Valdez	Court: Remarks were improper but brief and isolated; no fundamental, reversible error given overwhelming evidence of guilt
Sufficiency of proof of prior convictions for sentence enhancement	Certified conviction documents listing name, middle initial, and DOB (and SSNs on two) sufficiently establish identity by clear and convincing evidence	Name on records lacked "Jr."; reliance on name and DOB alone was insufficient to connect Eaton to out-of-state convictions	Court: Certified documents with name and DOB (and matching SSNs on two) plus absence of any challenge suffice; trial court did not abuse discretion; convictions proved

State v. Valdez, 160 Ariz. 9 (discussing impropriety of mentioning plea bargains in final argument)
State v. Moody, 208 Ariz. 424 (prosecutorial-misconduct review framework)
State v. Henderson, 210 Ariz. 561 (waiver and fundamental error standard for unobjected-to error)
State v. Kinney, 225 Ariz. 550 (certified prior convictions with name and DOB sufficient absent doubt)
State v. Cons, 208 Ariz. 409 (clear-and-convincing standard and positive identification for prior-conviction proofs)
Donnelly v. DeChristoforo, 416 U.S. 637 (misconduct must deny due process to warrant reversal)
State v. Jones, 197 Ariz. 290 (prosecutors’ broad latitude in closing argument)
State v. Hughes, 193 Ariz. 72 (misconduct reversal requires trial unfairness)