State v. Sales, 1 CA-CR 15-0788

Sales was charged (Dec 2013) with one count of sale of a dangerous drug (methamphetamine); arraigned Jan 9, 2014, released on conditions, and counsel was appointed.
Multiple defense counsel withdrawals and many continuances occurred for various reasons (conflicts of counsel, plea/disclosure issues, prosecutor illness/parental leave, calendar conflicts, and defense requests); Sales sometimes agreed and sometimes later objected.
Sales repeatedly sought delay relief, moved to dismiss five days before a November 2014 trial date alleging Rule 8 speedy-trial violations; trial court denied the motion finding delays were occasioned by or on behalf of Sales.
Shortly before trial Sales moved for new counsel alleging poor communication and threats; the court denied the request after finding no irreconcilable conflict.
Sales raised, the day before trial, that the trial judge had prosecuted a prior case involving him; the judge investigated and declined to recuse; trial proceeded and a jury convicted Sales; court imposed a mitigated eight-year sentence.

Issue	Plaintiff's Argument (Sales)	Defendant's Argument (State / Trial Court)	Held
Speedy-trial (Rule 8)	Continuances deprived Sales of his Rule 8 right; judge failed to make findings of extraordinary circumstances	Delays were largely occasioned by or on behalf of Sales or consented-to; any trial-court omissions were procedural and not fundamentally prejudicial	Affirmed: no fundamental error; delays excluded and no proven prejudice
Change of counsel	Counsel failed to communicate, threatened Sales, and relationship was irreparably fractured	Disagreement over strategy and poor communication (partly Sales’ fault) do not show a complete breakdown	Affirmed: no abuse of discretion; no irreconcilable conflict shown
Change of judge / recusal (Rule 10.1)	Judge prosecuted a prior case involving Sales and thus should be replaced or referred under Rule 10.1(c); additional comments showed bias	Sales did not file a verified motion under Rule 10.1; judge properly inquired and found no basis to recuse; remarks were judicial, not extrajudicial	Affirmed: Rule 10.1(c) not triggered; no fundamental error or bias established
Sentencing minute entry amendment	Minute entry incorrectly labeled sentence aggravated	Court orally imposed a mitigated 8-year term consistent with law	Modified minute entry to reflect mitigated sentence; conviction and sentence otherwise affirmed

State v. Hunter, 227 Ariz. 542 (appellate review standard for Rule 8 rulings)
State v. Spreitz, 190 Ariz. 129 (Rule 8 is procedural; delay dismissal not warranted absent foundational error)
State v. Zuck, 134 Ariz. 509 (defense counsel’s requests for continuances bind the defendant)
Doggett v. United States, 505 U.S. 647 (prejudice in speedy-trial context—anxiety is relevant but must be shown)
State v. Cromwell, 211 Ariz. 181 (standard for change-of-counsel: irreconcilable conflict required)
State v. Henderson, 210 Ariz. 561 (fundamental-error review framework)
State v. Bowles, 173 Ariz. 214 (oral pronouncement controls over clerical minute-entry errors)