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

Summary

The court affirmed Payne’s convictions and death sentences after rejecting challenges to jury selection, venue, post-arrest statements, and the exclusion of hearsay concerning Gonzales’s threats. It held that any error in the jury-selection process was nonstructural and nonprejudicial, that neither presumed nor actual venue prejudice was shown, that Payne’s pre-stationhouse request for counsel was anticipatory and ineffective, and that his later statements were admissible. The court also concluded that the excluded threats were either outside the asserted hearsay exceptions or properly excluded under the balancing rule.