State v. Martinez, 226 Ariz. 221

Martinez was convicted of possession of methamphetamine for sale and manufacturing a dangerous drug, with additional counts that were largely resolved by acquittals.
Police responding to a tip found a large, sophisticated meth lab at Martinez’s residence with lab equipment, solvents, and numerous bags and scales indicating distribution.
Carl, a purchaser of methamphetamine, testified Martinez sold him methamphetamine several times a week from the master bedroom and bathroom where production occurred.
The raid uncovered lab residues and materials in the master bedroom and bathroom, including pills in extraction and methamphetamine on a dresser, supporting manufacturing activity.
The trial court imposed consecutive sentences for possession for sale and manufacture of a dangerous drug, based on a finding of distinct societal harms from selling versus manufacturing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for possession for sale	Martinez argues the baggies reflect personal use, not sale.	Martinez contends evidence is insufficient to prove sale.	Substantial evidence supports sale conviction.
Consecutive sentences under Gordon framework	Consecutive sentences were improper because acts were part of a single transaction.	Two offenses constitute distinct harms justifying consecutives.	Consecutive sentences permitted; evidence shows distinct harms and separate risks.

State v. Mathers, 165 Ariz. 64 (1990) (standard for substantial evidence review)
State v. Stroud, 209 Ariz. 410 (2005) (standard for viewing evidence in sufficiency review)
State v. Arredondo, 155 Ariz. 314 (1987) (foundational sufficiency principles)
State v. Gordon, 161 Ariz. 308 (1989) (three-part Gordon test for consecutive sentences)
State v. Runningeagle, 176 Ariz. 59 (1993) (elaborates on Gordon framework application)
State v. Price, 218 Ariz. 311 (App. 2008) (contrast on consecutive sentencing where no residual risk remains)
State v. Thues, 203 Ariz. 339 (2002) (fundamental error review for illegal sentences)
State v. Henderson, 210 Ariz. 561 (2005) (fundamental error standard of review)