State v. Robertson, 440 P.3d 401

In 2002 Robertson was charged with first-degree murder and child abuse; counts were reduced under a plea agreement to manslaughter (prison) and reckless child abuse (probation).
Plea agreement stipulated to a consecutive structure: a prison term for manslaughter and a consecutive lifetime probation term for child abuse; agreement warned that violating probation could lead to sentencing "without limitation."
Robertson served her prison term and was released in 2010; she had multiple probation violations (2014, 2016, March 2017) and was repeatedly reinstated.
In May 2017 the State filed a petition alleging an intensive-probation violation; at the revocation hearing Robertson for the first time argued the consecutive sentence violated A.R.S. § 13-116 (prohibition on double punishment for the same act/victim).
The superior court revoked probation in July 2017 and imposed a presumptive 3.5-year prison term; Robertson appealed, challenging the legality of the sentence under § 13-116.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentencing after probation revocation violated A.R.S. § 13-116 (double punishment for same act/victim)	Robertson: consecutive sentence illegal because she previously served prison time for the same act and victim	State: plea agreement and stipulation authorized consecutive probation and potential imprisonment on violation; invited error/waiver bars challenge	Court: Invited-error doctrine bars Robertson's § 13-116 challenge because she knowingly stipulated to consecutive probation and the possibility of unlimited sentencing on violation; appeal affirmed

State v. Johnson, 210 Ariz. 438 (de novo review of sentence legality)
State v. Todd, 244 Ariz. 374 (de novo review of consecutive sentences under § 13-116)
State v. Martinez, 226 Ariz. 221 (illegal sentence is fundamental error)
State v. Regenold, 226 Ariz. 378 (appealability of sentence after contested probation-violation hearing)
State v. Logan, 200 Ariz. 564 (invited-error doctrine discussion)
State v. Rushing, 243 Ariz. 212 (invited error prevents profiting from injected record error)
State v. Parker, 231 Ariz. 391 (invited error from stipulations to evidence admission)
State v. Pandeli, 215 Ariz. 514 (invited error where defendant explicitly declined objection)
State v. Morse, 127 Ariz. 25 (plea agreement stipulations are agreements among defendant, counsel, and prosecutor)
State v. Escalante, 245 Ariz. 135 (invited-error doctrine precludes relief even when error is fundamental and prejudicial)