State of Arizona, Appellee v. Louie Thomas MacHado, Appellant

Summary

The court held that evidence offered to show third-party culpability is governed by the relevance and prejudice provisions of Rules 401 through 403, rather than the character-evidence restriction in Rule 404(b). It also held that an anonymous telephone confession was admissible under the statement-against-interest hearsay exception and was sufficiently relevant and trustworthy. Because the trial court improperly excluded both categories of evidence, the court reversed the murder conviction and remanded for further proceedings.