State v. Lehr, 227 Ariz. 140

Lehr abducted, sexually assaulted, and murdered multiple women in Phoenix from 1991 to 1993, leading to convictions on murder, kidnapping, and sexual assault offenses.
He received death sentences for M.M. and M.C. murders, and a death sentence for B.C. was vacated and resentenced to life after Ring v. Arizona mandated resentencing.
Counts involving M.M., M.C., and W.C. were retried in 2009; the jury again sentenced Lehr to death for M.M. and M.C., but the B.C. sentence was resolved with life imprisonment due to inability to reach a verdict on aggravation for B.C.
Lehr challenged numerous aspects on appeal, including trial attendence waivers, admission of other-acts evidence, confrontation issues, DNA testing, juror conduct, premeditation instructions, and mid-trial amendments to aggravating factors.
This Court independently reviews aggravation and mitigation due to pre- Ring era murders, weighing aggravators and mitigators de novo.
The Arizona Supreme Court ultimately affirmed Lehr’s convictions and sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of Lehr's trial attendance waiver	Waiver was involuntary due to stun belt policy and coercive conduct.	Waiver was knowing, intelligent, and voluntary; policy did not compel invalid waiver.	Waiver was valid; no error found.
Admission of other acts evidence and joinder	404(b)/(c) evidence and joinder were improper and prejudicial.	Evidence properly admitted for MO/identity/aberrant propensity; joinder appropriate.	Court did not abuse its discretion; admission and joinder were proper.
Confrontation rights with unavailable witness	Reading prior testimony violated confrontation.	Witness unavailable; prior testimony admissible under Rule 19.3 and Crawford.	No Confrontation Clause violation; admissible.
Amendment of notice of aggravating factors mid-trial	Mid-trial amendment violated Rule 13.5 and due process.	Amendment harmless; Lehr had notice and no prejudice to defense.	Amendment harmless beyond a reasonable doubt; no due process violation.

Deck v. Missouri, 544 U.S. 622 (2005) (case-specific proceedings and security considerations in trial context)
Ring v. Arizona, 536 U.S. 584 (2002) (required jury determination of aggravating factors in capital cases)
Thompson, 204 Ariz. 471 (2003) (premeditation instruction standards; time vs. reflection evidence)
Freeney, 223 Ariz. 110 (2009) (harmless error analysis for improper aggravation-factor notices)
Ellison, 213 Ariz. 116 (2006) (unanimity and mitigation/proportionality standards in sentencing)
Glassel, 211 Ariz. 33 (2005) (victim impact and mitigating evidence considerations in capital sentencing)
Bocharski II, 218 Ariz. 476 (2008) (jurisdictional and evidentiary handling in capital cases)