State v. Martinez, 230 Ariz. 382

Martinez was convicted of one count of unlawful flight from a pursuing official vehicle under A.R.S. § 28-622.01 after a traffic stop and pursuit where the driver fled.
Officer Shipley stopped a black Chevy pickup; license was suspended and the driver fled the scene, with Shipley later identifying Martinez as the driver.
Martinez gave inconsistent explanations about the truck being stolen, which led to his arrest by Officer Fortune who had been responding to a stolen-vehicle report.
At trial, Officers Shipley and Fortune testified; the jury found Martinez guilty, and the court suspended sentence and placed him on probation.
Martinez appealed arguing insufficient evidence and improper admission of opinion testimony about his truthfulness, raising two core issues.
The Arizona Court of Appeals affirmed, addressing statutory interpretation of unlawful flight elements and the admissibility of opinion testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether flight requires emergency-light activation	Martinez contends lights must be activated to prove unlawful flight.	State contends lights are not an essential element; police vehicles exempt from front-visibility light requirements.	Lights not required; unlawful flight proved by elements including marked police vehicle.
Admission of Officer Fortune's opinion on Martinez's truthfulness	Martinez argues the testimony invaded jury's credibility determination as improper opinion.	State argues testimony was permissible to explain investigative actions and was not fundamental error.	Not fundamental error; jury instructed on credibility and evidence viewed in light of the record.
Sufficiency of the evidence supporting unlawful flight	Martinez asserts insufficient evidence of wilful flight and pursuit in a marked vehicle.	State argues evidence shows Martinez fled from an authorized emergency vehicle and the vehicle was marked.	Evidence sufficient to prove all elements of unlawful flight, including vehicle being an authorized police vehicle.

State v. Fogarty, 178 Ariz. 170 (App. 1993) (defining element framework for unlawful flight involving an authorized vehicle)
In re Joel, 200 Ariz. 512 (App. 2001) (lights/siren not essential element for unlawful flight in some contexts)
State v. Reimer, 189 Ariz. 239 (App. 1997) (limits on lay/experts giving truthfulness opinions)
Doerr, 193 Ariz. 56 (2000) (permissible lay opinion when rational and aids understanding)
State v. Henderson, 210 Ariz. 561 (2005) (fundamental error review framework for unobjected-to conduct)
State v. Morale s / Morales, 198 Ariz. 372 (App. 2000) (principles for evaluating unobjected-to errors)
State v. Newell, 212 Ariz. 389 (2006) (jury credibility instruction presumed followed)