State v. Satzman, 1 CA-CR 16-0861

Background

Defendant Stacy Lee Satzman was tried for arson of a structure (convicted) and misconduct involving weapons (acquitted); sentence 12 years after jury found two aggravators and court found four prior felonies.
During voir dire, several prospective jurors made statements suggesting bias or knowledge of the defendant; the court excused some for cause but seated 23 jurors after follow-up rehabilitation questions.
Satzman objected to specific jurors (L.S., E.R., C.C.) who initially said the defendant should present evidence; the court asked whether they could follow the law that the defendant need not present evidence and each answered affirmatively.
Satzman later argued the entire venire was tainted by multiple overheard or voiced comments about the defendant and by the small proportion of summoned jurors who appeared (about 59 of 140).
Satzman also challenged the court’s instruction on juror-submitted questions to witnesses, arguing the court should have reminded jurors after each witness rather than giving only an initial instruction.
The court denied cause strikes for L.S., E.R., and C.C., refused to sua sponte dismiss the whole venire, and found the jury-question instruction adequate; the Court of Appeals affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by not excusing jurors L.S., E.R., C.C. for cause	Satzman: jurors’ initial statements that defendant should present evidence showed bias and required excusal	Court/State: jurors were rehabilitated by follow-up instruction and said they could follow the law; no further questioning pursued by defense	No abuse of discretion; jurors adequately rehabilitated and could follow law
Whether trial court should have dismissed entire jury pool sua sponte	Satzman: multiple overheard/voiced comments revealed pervasive taint and unfair venire, compounded by low turnout	Court/State: prejudicial effect not demonstrated; offending jurors were excused and court probed for other taint; speculation insufficient	No fundamental error; record fails to show venire was irreparably tainted
Whether failure to repeatedly instruct jurors on submitting questions to witnesses violated Rule 18.6(e)	Satzman: court should have reminded jurors after each witness so defense could address jurors’ concerns	Court/State: initial instruction complied with rule and comment; no duty to re-prompt after each witness	Instruction sufficient; no error (and no fundamental prejudice shown)
Standard of review for claimed jury-selection errors	Satzman: urged relief for biased jurors/venire	Court/State: appellate review for abuse of discretion; unobjected errors reviewed for fundamental error under Henderson	Court applied abuse-of-discretion for for-cause rulings and fundamental-error review for unpreserved venire/instruction claims; defendant failed to meet burden

Key Cases Cited

State v. Poland, 144 Ariz. 388 (juror with preconceived opinions may serve if willing to follow law)
State v. Hoskins, 199 Ariz. 127 (trial court best positioned to judge juror credibility)
State v. Glassel, 211 Ariz. 33 (abuse-of-discretion review for strikes for cause)
State v. Lujan, 184 Ariz. 556 (defendant entitled to fair jury but not any particular jury)
State v. Henderson, 210 Ariz. 561 (fundamental-error standard for unpreserved claims)
State v. Moreno-Medrano, 218 Ariz. 349 (must show prejudice; fundamental-error burden on defendant)
State v. Doerr, 193 Ariz. 56 (juror prejudice not presumed; requires objective evidence)
State v. Davis, 137 Ariz. 551 (court will not assume panel was tainted absent proof)
State v. Aguilar, 209 Ariz. 40 (comments may clarify rule but cannot change rule text)