State v. Trujillo, 430 P.3d 379

Defendant Oscar Trujillo, a youth-care worker at a Tucson refugee facility, was convicted by a jury of one count of sexual abuse for touching a 15‑year‑old resident over clothing.
Trial court suspended sentence and placed Trujillo on three years’ probation, and ordered sex‑offender registration under A.R.S. § 13‑3821(A)(3) (registration required for sexual abuse if victim is under 18).
Trujillo objected post‑sentence, arguing Apprendi v. New Jersey required a jury finding of the victim’s age before imposing registration and filed a motion to modify sentence.
Trial court denied the motion, deferred registration pending appeal, and this appeal followed.
Trujillo also appealed the trial court’s preclusion of evidence that a State witness‑supervisor was later terminated from employment (argued as impeachment/credibility evidence).

Issue	Trujillo's Argument	State's Argument	Held
Whether Apprendi requires a jury finding of victim’s age before court can order registration under § 13‑3821(A)(3)	Apprendi and progeny require any fact that increases punishment beyond statutory maximum be found by a jury; registration is a penalty so victim’s age must be jury‑found	Registration is regulatory (not a sentence enhancement) and § 13‑3821(A)(3) has no statutory maximum/mandatory minimum subject to Apprendi	Court held Apprendi does not apply: registration is regulatory for Apprendi purposes (and even if punitive, it does not increase a statutory maximum), so the court may find victim’s age; any error would also be harmless given uncontested evidence the victim was 15 when offended
Whether exclusion of evidence that State witness‑supervisor was later fired was erroneous (impeachment)	Evidence showed supervisor also violated rules, so it was relevant to credibility and to show rule noncompliance was common	Termination was unrelated (different policy), remote in time, not probative of truthfulness, and risked confusion/prejudice	Court upheld exclusion under Ariz. R. Evid. 403: evidence was marginally relevant, remote, and did not show untruthfulness, so exclusion was not an abuse of discretion

Apprendi v. New Jersey, 530 U.S. 466 (any fact that increases penalty beyond statutory maximum must be submitted to a jury)
Southern Union Co. v. United States, 567 U.S. 343 (Apprendi rule extends to criminal fines; courts treat fines as penalties)
State v. Noble, 171 Ariz. 171 (1992) (Arizona Supreme Court treated § 13‑3821 as nonpunitive under Mendoza‑Martinez analysis)
Fushek v. State, 218 Ariz. 285 (2008) (sex‑offender registration may be sufficiently severe to implicate jury‑trial considerations under state analysis)
Smith v. Doe, 538 U.S. 84 (2003) (Alaska SORA is civil/ regulatory; retroactive application not punitive)
Blanton v. City of North Las Vegas, 489 U.S. 538 (serious vs. petty offense test for jury‑trial right considers maximum authorized penalty and attached collateral consequences)