State v. MacHado, 226 Ariz. 281

Rebecca R. was shot and killed after returning home from a church party; initial suspect was Jonathan H., a classmate and ex-boyfriend of Rebecca's friend.
An anonymous caller later claimed to have killed Rebecca and provided details not public; police sought a voice sample from Jonathan but never used it.
Years later, Machado became a suspect; his mother testified he confessed and later recanted; a neighbor saw Machado near the murder scene.
Machado was charged with murder; his defense argued Jonathan committed the crime and presented third-party culpability evidence.
Superior Court admitted some Jonathan-related acts (death threat, inconsistencies, restraining order) but excluded other acts and the anonymous call; Machado was convicted of second-degree murder.
Court of Appeals reversed, holding excluded third-party acts and the anonymous call should have been admitted; the Supreme Court granted review to decide the admissibility framework for third-party culpability evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Rule 404(b) apply to third-party culpability evidence?	State: Rule 404(b) applies to third-party acts offered to show someone else committed the crime.	Machado: Rule 404(b) does not govern third-party culpability evidence; Rules 401-403 apply.	Rule 404(b) does not govern third-party culpability evidence; Rules 401–403 apply.
Is the anonymous telephone call admissible as a hearsay exception or otherwise?	State: call tends to exculpate Machado and is potentially admissible under Rule 804(b)(3) with corroboration.	Machado: call is unreliable hearsay and not within 804(b)(3) or corroboration rules.	Call is hearsay but admissible under Rule 804(b)(3) with corroboration; corroboration supports trustworthiness.
Was the telephone-call testimony properly evaluated under Rule 403 balancing?	Call has strong probative value on who committed the crime and is directly relevant.	Call risks unfair prejudice; probative value is outweighed by danger of confusion.	Probative value not substantially outweighed by prejudicial effect; admissible.

State v. Tankersley, 191 Ariz. 359 (Ariz. 1998) (Rule 404(b) applies to third-party acts offered by a defendant)
State v. Gibson, 202 Ariz. 321 (Ariz. 2002) (use Rules 401–403 to assess third-party culpability evidence)
State v. Prion, 203 Ariz. 157 (Ariz. 2002) (third-party culpability evidence must be relevant and weighed under Rule 403)
State v. Terrazas, 189 Ariz. 580 (Ariz. 1997) (clear and convincing standard for other acts offered under Rule 404(b))
State v. Fish, 222 Ariz. 109 (Ariz. App. 2009) (cites application of Rule 404(b) to third-party acts)