State v. Woods
1 CA-CR 15-0414
| Ariz. Ct. App. | Sep 29, 2016Background
- On July 25, 2012, Christopher Woods, co-defendant Leroy Jackson, and two others drove to buy marijuana; Woods and Jackson donned masks and kept watch outside the seller’s house while Jackson forced entry.
- Jackson fired three shots during the intrusion; one shot killed the seller, David. Woods admitted he was keeping watch and later said the shooting “wasn’t supposed to happen like that.”
- Woods was tried by jury and convicted of first degree felony murder (felony-murder based on attempted armed robbery), attempted armed robbery, and conspiracy to commit possession of marijuana. Jackson pleaded to second-degree murder in a separate disposition.
- Woods received concurrent sentences: life with parole eligibility after 25 years for felony murder; 10.5 years for attempted armed robbery; and 1 year for the conspiracy conviction; 1009 days’ presentence credit was awarded.
- Counsel filed an Anders brief; Woods filed a pro se supplemental brief conceding the conspiracy but arguing he was merely present for the robbery and murder. The appellate court affirmed convictions but found and corrected a sentencing error as to attempted armed robbery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for murder and attempted armed robbery | State: Evidence (masks, gloves, Woods kept watch, his admissions, phone/Walgreens footage) shows Woods aided and agreed to the attempted robbery and is liable for Jackson’s lethal act as a foreseeable consequence | Woods: He was merely present and did not participate; convictions based largely on his statements violate corpus delicti rule | Conviction affirmed: circumstantial evidence corroborated his admissions; accomplice liability and foreseeability apply |
| Corpus delicti / reliance on confession | State: Independent circumstantial evidence (Scott’s testimony, video, phone data) established corpus delicti before considering Woods’ statements | Woods: Cannot be convicted solely on uncorroborated confession; corpus delicti not proven | Held: Corpus delicti established by independent evidence; confession admissible as corroborated |
| Sentencing that exceeded lawful range for attempted offense | State: Sentence within dangerous-felony range but court announced intention to impose presumptive term | Woods: Court sentenced him as if convicted of completed armed robbery (more serious) rather than attempted offense | Error found and corrected: sentence for attempted armed robbery modified to presumptive 7.5 years to reflect court’s intent |
| Anders procedural review / fundamental error standard | State: Court to conduct independent review for fundamental error after Anders brief | Woods: Raised pro se claims (e.g., factual insufficiency) | Court conducted exhaustive review; no fundamental error except sentencing mismatch; remainder affirmed |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (establishes counsel’s duty to advise and appellate court’s independent review when counsel seeks to withdraw)
- State v. Leon, 104 Ariz. 297 (1969) (requires appellate court to search the record for fundamental error following Anders filing)
- State v. Henderson, 210 Ariz. 561 (2005) (defines fundamental error standard on appeal)
- State v. Hall, 204 Ariz. 442 (2003) (discusses corpus delicti rule and need for independent corroboration of confessions)
- State v. Cox, 201 Ariz. 464 (2002) (holding that failure to follow mandatory sentencing statutes produces an illegal sentence)