State v. Isiah Patterson, 283 P.3d 1

Isiah Patterson was convicted of first-degree murder of Consquelo Barker and sentenced to death in 2009.
The crime occurred around 1:30 a.m. on March 17, 2006, at Patterson’s Mesa apartment; Patterson stabbed Barker thirteen times.
Patterson and Barker were in a domestic dispute involving their three-year-old child; Barker died after fleeing to a bush outside the complex.
Patterson was charged in Maricopa County and pursued the death penalty; the State sought capital punishment and the jury found aggravating factors justifying death.
Patterson appealed the death sentence, challenging voir dire, juror strikes, alleged prosecutorial misconduct, instruction errors, and mitigation considerations.
The Arizona Supreme Court reviews the automatic appeal for abuse of discretion and deference to trial court judgments under Arizona law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voir dire: scope of juror questioning	Patterson argues trial court restricted death-penalty voir dire beyond Morgan.	State contends court properly limited questions about aggravating/mitigating factors.	No reversible error; court allowed broad probing of death-penalty views and adherence to law.
Hypothetical mitigation question	Patterson claims improper requirement to mention mitigation in hypothetical.	State argues court’s clarification prevented confusion and preserved impartiality.	No abuse; court’s instruction preserved impartiality and did not prejudice Patterson.
Mistrial for prosecutorial misconduct and late disclosure	Prosecutor’s demeanor and late PowerPoint misstatement warranted mistrial.	State contends conduct was not pervasive misconduct and late disclosure cured error.	No abuse; no prejudice shown; late disclosure cured misstatement; no mistrial required.
Lesser included offense: manslaughter	Evidence supported a manslaughter instruction due to provocation.	No adequate provocation evidence to support a manslaughter instruction.	No error; trial court properly declined manslaughter instruction.
Dangerousness aggravator in guilt phase	Inclusion of non-capital aggravator in guilt phase violated Rule 19.1 and due process.	Defense acknowledges error but argues harmless; evidence of dangerousness mirrored murder.	Harmless error; jury would have found the underlying murder as sufficient for death sentence.

Morgan v. Illinois, 504 U.S. 719 (1992) (due process requires inquiry into automatic death-penalty predisposition)
State v. Glassel, 211 Ariz. 33 (2005) (limits voir dire on aggravation/mitigation; allows broader death-penalty inquiry)
State v. Henderson, 210 Ariz. 561 (2005) (abuse-of-discretion standard for trial rulings; important for voir dire)
State v. Kreutzer, 928 S.W.2d 854 (Mo. 1996) (trial court may constrain confusing voir dire questions; preserves impartiality)
State v. Ellison, 213 Ariz. 116 (2006) (unanimity and mitigation standards in assessing substantial evidence)