The State of Arizona, Appellee v. Christopher Mathew Payne, Appellant

Summary

The Arizona Supreme Court affirmed Christopher Mathew Payne's convictions for two counts of first degree murder, three counts of child abuse, and two counts of concealing a dead body, along with the death sentences imposed for each murder, rejecting challenges to jury selection, venue, Miranda rulings, hearsay exclusion, other-acts evidence, restraint exposure, child-abuse elements and duplicity, sufficiency of the premeditation evidence, juror misconduct, prosecutorial misconduct, aggravation-phase instructions, mitigation preclusions, and penalty-phase rebuttal evidence. The court announced that Miranda rights cannot be invoked anticipatorily in a non-custodial setting, that the mens rea in A.R.S. § 13-3623(A) does not extend to the "circumstances likely to produce death or serious physical injury" clause, and that brief, inadvertent juror exposure to a shackled defendant outside the courtroom is not inherently prejudicial. It held the erroneous exclusion of Payne's "good inmate" mitigation evidence harmless beyond a reasonable doubt and sustained all three aggravators and both death sentences under abuse-of-discretion review. Vice Chief Justice Bales concurred in the affirmance of the convictions but dissented from the harmlessness ruling, would have vacated the death sentences, and would have remanded for a new penalty phase admitting the good-inmate evidence.