State v. Skaro, 1 CA-CR 17-0005

On January 6, 2016, officers stopped a sedan driven by Jamie Kay Skaro after observing traffic violations; Skaro produced a marijuana cigarette and discarded a stun gun into the trunk.
Officers found a meth pipe on Skaro, multiple baggies of methamphetamine in her coat, and oxycodone in a prescription bottle in her purse; Skaro led officers to marijuana and a surveillance monitor in her bedroom.
Skaro made several admissions: she possessed methamphetamine (claimed for personal use), possessed the marijuana (asserted she had a medical card), possessed the oxycodone bottle (claimed she was returning it for a friend), and admitted the pipe was for methamphetamine.
A jury convicted Skaro of: possession of dangerous drugs for sale (methamphetamine, Class 2), possession of narcotic drugs (oxycodone, Class 4), possession of marijuana (Class 6), and possession of drug paraphernalia (Class 6).
The jury found an aggravating factor (commission for pecuniary consideration). Sentences were within statutory ranges: aggravated 12 years for the Class 2 count, concurrent mitigated terms on other counts, presentence credit, community supervision, and fines.
Counsel filed an Anders brief asserting no arguable appellate issues; the court conducted a full record review for fundamental error and affirmed convictions and sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that methamphetamine was possessed for sale	State: quantity, separate baggies, packaging, surveillance monitor, and admissions supported sale inference	Skaro: argued meth was for personal use; denied sale intent	Affirmed — evidence (direct and circumstantial) was sufficient for jury to find possession for sale
Admission and post-stop statements admissibility (Miranda)	State: statements and admissions were properly obtained and admissible	Skaro: implied challenge to statements' voluntariness/consent (no preserved reversible error)	Affirmed — no reversible error found in record review; Miranda warnings were given and proceedings were proper
Ownership/possession of oxycodone bottle	State: custody of bottle and identification of pills supported possession	Skaro: claimed she was returning the bottle to its owner; offered no independent proof of owner	Affirmed — jury credited State evidence over Skaro's uncorroborated assertion
Sentencing within statutory bounds and procedure	State: sentencing followed Rule 26 and constitutional protections; aggravator supported	Skaro: challenged sentence severity and aggravator (implicit)	Affirmed — sentencing complied with rules, mitigations and aggravations considered, terms within statutory guidelines

Anders v. California, 386 U.S. 738 (U.S. 1967) (establishes counsel's duty to advise and appellate court's obligation to review record when counsel files no-issue brief)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requirements for custodial interrogation warnings)
State v. Leon, 104 Ariz. 297 (Ariz. 1969) (procedure for appellate review when counsel finds no arguable issues)
State v. Fontes, 195 Ariz. 229 (Ariz. App. 1999) (standard for viewing facts in the light most favorable to sustaining a conviction)
State v. Flores, 227 Ariz. 509 (Ariz. App. 2011) (standard for fundamental-error review)
State v. Shattuck, 140 Ariz. 582 (Ariz. 1984) (counsel's duties to client after appellate disposition and procedures for petitions for review)