State v. Halterman, 1 CA-CR 21-0146

In 2016–2017, 28‑year‑old Jerad Halterman exchanged sexual Facebook messages with Ariana, then 15, including two photos of his penis and a masturbation video.
Halterman met Ariana at her grandfather’s truck, digitally penetrated her, and had her masturbate his penis; he later admitted intercourse with her when she was about 13.
Detectives obtained Facebook records by warrant; Halterman admitted sending the images before Miranda warnings and admitted sexual acts after waiving Miranda at the station.
The State charged multiple counts including sexual conduct with a minor, luring offenses, and two counts of sexual conduct with a minor under 15; one under‑15 count was dismissed at trial and one survived.
Pretrial motions: voluntariness hearing found statements voluntary; motion in limine was granted in part but the State was allowed to use the photos, video, and certain statements; severance was denied.
Jury convicted on the remaining counts; court found Halterman a category‑three repetitive offender and imposed concurrent and consecutive aggravated terms (including 21 calendar years for the under‑15 conviction), with presentence credit applied.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Halterman)	Held
Sufficiency of evidence for sexual conduct with a minor under 15	Evidence and Halterman’s admissions show intercourse when victim ~13	Argued insufficient evidence to prove victim was under 15 at time of intercourse	Guilty verdict supported; admissions and victim testimony sufficient
Voluntariness of custodial statements	Statements were voluntary; admissible	Argued statements should be excluded as involuntary or improperly obtained	Court found statements voluntary after hearing; admissible
Admissibility of photos/video and statements (motion in limine)	Photos/video and certain statements were relevant and admissible	Sought to exclude statements, photos, video	Court granted motion in part but permitted use of photos, video, and statements that he had been to prison; trial proceeded
Motion to sever under‑15 counts from other charges	Joinder was appropriate	Sought severance of under‑15 counts	Court denied severance; no reversible error shown

Anders v. California, 386 U.S. 738 (1967) (procedures for appointed counsel to seek withdrawal when appeal lacks arguable issues)
Penson v. Ohio, 488 U.S. 75 (1988) (appellate duty to independently review record when counsel files an Anders brief)
State v. Leon, 104 Ariz. 297 (1969) (Arizona counterpart to Anders review procedure)
State v. Clark, 196 Ariz. 530 (App. 1999) (standard for appellate review following Anders/Leon filing)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda rights and custodial interrogation rules)
State v. Mendoza, 248 Ariz. 6 (2019) (viewing trial facts in the light most favorable to sustaining verdict)
State v. Shattuck, 140 Ariz. 582 (1984) (counsel’s post‑appeal duties to inform client of outcome and options)
State v. Dawson, 164 Ariz. 278 (1990) (appellate court lacks jurisdiction to correct an illegally lenient sentence absent State appeal)