State of Arizona, Appellee v. Samkeita Jahveh Jurden, Appellant

Summary

The court held that Arizona’s resisting-arrest statute permits only one conviction when resistance occurs during a single, uninterrupted arrest event, regardless of the number of officers involved. Because the statute is ambiguous as to whether the unit of prosecution is the event or each officer resisted, the court applied statutory context, purpose, structure, and lenity principles and concluded that multiple convictions violated double jeopardy. The court vacated the second resisting-arrest conviction, affirmed the remaining convictions and sentences, and vacated the court of appeals’ opinion.