State of Arizona v. Samkeita Jahveh Jurden

Summary

The Arizona Supreme Court held that Arizona’s resisting-arrest statute, A.R.S. § 13-2508, permits only one conviction when the resistance occurs during a single, uninterrupted course of conduct, regardless of the number of officers involved. The court concluded that multiple convictions and punishments in those circumstances violate double-jeopardy protections. It vacated the second resisting-arrest conviction, affirmed the remaining convictions and sentences, and vacated the court of appeals’ opinion.

Holdings

1. A.R.S. § 13-2508 establishes an event-directed unit of prosecution. Regardless of the number of officers involved, a defendant may receive only one resisting-arrest conviction when the resistance occurs during a single, continuous event.
2. Multiple convictions and punishments under A.R.S. § 13-2508 for a single, continuous act of resisting arrest violate the Double Jeopardy Clause.

Questions Presented

1. Whether Arizona Revised Statutes § 13-2508 permits multiple convictions for resisting arrest when the defendant's resistance involves multiple officers during one uninterrupted course of conduct.
2. Whether multiple resisting-arrest convictions arising from that single continuous event violate the Double Jeopardy Clause.

Disposition

other