State v. Soza, 464 P.3d 696

During a traffic stop, Andrew Soza gave a false name and was arrested for false reporting; a search incident to arrest found two small micro-baggies on his person.
Officers impounded and searched the vehicle; the trunk contained packages of methamphetamine and heroin, a glass pipe, multiple micro-baggies, and a digital scale with residue.
The State charged Soza with: possessing dangerous drugs for sale (meth), possessing narcotic drugs for sale (heroin), four counts of possessing drug paraphernalia (micro-baggies for meth, micro-baggies for heroin, a scale for meth, the same scale for heroin), and false reporting.
A jury convicted Soza on all counts; the superior court sentenced him to concurrent prison terms (longest 15.75 years) and Soza appealed.
The principal legal question was the allowable unit of prosecution under A.R.S. § 13-3415(A) (possession of drug paraphernalia) and whether multiple items simultaneously possessed support multiple convictions without violating double jeopardy.
The Court of Appeals held that simultaneous possession of multiple paraphernalia items constitutes a single violation of § 13-3415(A); it vacated three paraphernalia convictions and affirmed the remaining convictions and sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unit of prosecution under A.R.S. § 13-3415(A) and double jeopardy	Each object of paraphernalia is a separate offense; multiple items can support multiple convictions (State).	The allowable unit is the single act of possession—simultaneous possession of multiple items is one offense (Soza).	The court adopted an act-based unit: one prosecutable violation for simultaneous possession of paraphernalia; three paraphernalia convictions vacated.
Use of prior convictions for impeachment and counsel's questioning	N/A (prosecution limited impeachment to three priors and objected to defense questions)	Soza argues the court’s sidebar ruling prevented rehabilitation of credibility by discussing acceptance of responsibility for priors.	No reversible error: the jury already heard that Soza pled guilty; the sidebar ruling had no practical consequence.

State v. Jurden, 239 Ariz. 526 (discussing double jeopardy and allowable unit of prosecution)
United States v. Universal C.I.T. Credit Corp., 344 U.S. 218 (defining allowable unit of prosecution concept)
State v. O’Laughlin, 239 Ariz. 398 (holding possession-of-tools statute is not object-based; number of tools doesn’t create separate offenses)
State v. Gutierrez, 240 Ariz. 460 (permitting separate charges for each weapon where each increases danger)
Ball v. United States, 470 U.S. 856 (second conviction for same offense must be vacated even if sentences are concurrent)
State v. Williams, 232 Ariz. 158 (applying Ball principle to vacate duplicate convictions)