State v. Peterkin, 1 CA-CR 15-0697

Peterkin was observed taking a heavily taped package into a post office; a detective saw her add more tape and questioned her; she said the package belonged to someone else and denied knowing its contents.
The detective obtained Peterkin's consent to search her car; he found two cell phones, another taped package in the trunk, marijuana residue, and a marijuana odor.
A narcotics K-9 alerted to both the package Peterkin carried into the post office and the package in her trunk; lab testing showed the two packages contained about 17 pounds of marijuana.
Peterkin was indicted on possession for sale and sale/transportation of marijuana (Class 2 felonies); the jury convicted her of sale/transportation (amount > 2 lbs) and deadlocked on possession (dismissed without prejudice).
The superior court sentenced Peterkin to four years' incarceration with 411 days' presentence credit; she timely appealed via a counsel-led Anders brief asserting no non-frivolous issues.
The court conducted an independent review for fundamental error, found none, and affirmed the conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of search/consent and admission of evidence	State: consent to search and K-9 alerts justified seizure and admission of packages	Peterkin: (implicit) challenge to search/possession attribution; counsel raised no viable issue	Court found record supports consent, K-9 alerts, and evidence sufficient to support conviction
Voluntariness of statements	State: no issue raised; statements admitted	Peterkin: no contention in record that statements were involuntary	Court noted no indicia of involuntariness and declined to require a voluntariness hearing
Sufficiency of evidence for sale/transportation	State: circumstantial and direct evidence supported jury verdict	Peterkin: contested factual culpability but no preserved legal sufficiency claim on appeal	Court held evidence (K-9 alerts, marijuana in car, taped packages, amount) was sufficient for conviction
Jury composition, instructions, unanimity, sentencing procedures	State: trial procedures were proper	Peterkin: no preserved procedural claim	Court found jury properly constituted and instructed, verdict unanimous, sentencing lawful

Anders v. California, 386 U.S. 738 (1967) (establishes counsel’s duties when seeking to withdraw on appeal)
Smith v. Robbins, 528 U.S. 259 (2000) (counsel’s obligations under Anders framework clarified)
State v. Leon, 104 Ariz. 297 (1969) (Arizona’s Anders analog and appellate review procedure)
State v. Clark, 196 Ariz. 530 (App. 1999) (procedures for Anders brief in Arizona appellate practice)
State v. Smith, 114 Ariz. 415 (1977) (voluntariness of statements standard)
State v. Finn, 111 Ariz. 271 (1974) (voluntariness and waiver principles)
State v. Fontes, 195 Ariz. 229 (App. 1998) (viewing facts in light most favorable to sustaining verdict)
State v. Shattuck, 140 Ariz. 582 (1984) (counsel’s post-appeal obligations to client and notice of appellate options)