State of Arizona, Appellee v. Frank R. Maldonado, Appellant

Summary

The court held that the State’s failure to file an information before trial did not deprive the superior court of subject matter jurisdiction. The filing requirement protects a waivable personal constitutional right rather than defining the court’s jurisdiction, and Maldonado’s unpreserved claim therefore was reviewed for fundamental error; because he had notice of the charge and showed no prejudice, his conviction and sentence were affirmed. The court vacated the court of appeals’ opinion.