State v. Stelmasek, 1 CA-CR 15-0393

Background

Laura Stelmasek was convicted of first‑degree murder, conspiracy to commit murder, tampering with physical evidence, and concealing a dead body for her husband’s June 2011 killing; she was sentenced to life plus additional terms and appealed.
Stelmasek had exchanged numerous emails with Marzet Farris expressing a desire to be together and discussing plans to kill her husband; she also told Farris where weapons were kept in the home.
The victim’s body, with numerous stab wounds, was found wrapped in blankets in the family van at the Albuquerque airport; significant decomposition limited injury analysis.
Evidence at trial included a June 1 store receipt for a stun gun/pepper spray, cell‑tower and phone‑call records linking Stelmasek’s phone near the store at purchase time, and testimony that decomposition could obscure stun‑gun marks.
Farris was arrested and later testified he had lied during a prior police interview; the State pursued accomplice liability and conspiracy theories against Stelmasek.
Stelmasek appealed, challenging (1) admission of the stun‑gun purchase evidence, (2) exclusion of Farris’s pretrial interview statements, and (3) exclusion of Farris’s prior‑acts evidence; the court affirmed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Stelmasek)	Held
Admissibility of stun‑gun purchase evidence	Evidence of purchase is relevant to intent, aiding, and conspiracy; foundation sufficient via circumstantial proof	Receipt and store evidence irrelevant because no proof the stun gun was used and no direct proof Stelmasek purchased it	Admission proper: receipt relevant to intent/conspiracy and circumstantial evidence (calls, cell‑tower) provided sufficient authentication
Preclusion of Farris’s police‑interview statements (Rule 804(b)(3))	Statements were unreliable and contradicted by Farris’s trial testimony and other corroborating evidence; not sufficiently trustworthy	Statements would exculpate Stelmasek and should be admitted as statements against interest	Exclusion proper: although circumstantially against interest, corroborating circumstances did not clearly indicate trustworthiness; evidence contradicted by emails and conduct
Exclusion of Farris’s other‑acts evidence (prior assaults)	Not contested by State as to Farris’s violence; relevant to third‑party culpability only if it tends to create reasonable doubt about Stelmasek	Prior acts show Farris’s violent, manipulative nature and support theory he acted alone	Exclusion proper: evidence would not exculpate Stelmasek (at most shows Farris’s culpability but not that someone else, not Stelmasek, committed the crimes); exclusion—if erroneous—harmless and cumulative
Restitution order (funeral/travel costs)	Restitution awarded below	Stelmasek challenged amount	Appeal consolidated; court affirmed convictions and sentences (restitution appeal consolidated; no reversible error found)

Key Cases Cited

State v. Ellison, 213 Ariz. 116 (2006) (standard of review for evidentiary rulings)
State v. Rodriguez, 186 Ariz. 240 (1996) (deference to trial court on admissibility and relevance)
State v. George, 206 Ariz. 436 (App. 2003) (authentication standard for proponent of evidence)
State v. Best, 146 Ariz. 1 (App. 1985) (circumstantial evidence may satisfy authentication)
State v. Lavers, 168 Ariz. 376 (1991) (use of corroborating evidence for authenticity)
State v. Wooten, 193 Ariz. 357 (App. 1998) (jury may reasonably conclude authenticity from circumstantial proof)
State v. Prion, 203 Ariz. 157 (2002) (third‑party culpability evidence reviewed for abuse of discretion and relevance)
State v. Machado, 224 Ariz. 343 (App. 2010) (hearsay rules apply to third‑party culpability evidence)
State v. Alvarez, 228 Ariz. 579 (App. 2012) (third‑party evidence relevant only if it tends to create reasonable doubt)
State v. Dunlap, 187 Ariz. 441 (App. 1996) (exclusion of cumulative evidence harmless beyond a reasonable doubt)
State v. Anthony, 218 Ariz. 439 (2008) (harmless‑error analysis for evidentiary rulings)