State of Arizona, Respondent v. Brad Alan Bowsher, Petitioner

Summary

The court held that Arizona law authorizes trial courts to impose consecutive probation terms for convictions arising from either the same indictment or separate indictments. It reached that conclusion by applying the plain meaning of the governing statute, considering legislative history, and rejecting contrary reasoning from an earlier statutory regime. The court also rejected the defendant’s due process argument because the statutory enactment made the result foreseeable and the prior precedent did not support reliance on a contrary rule.