State of Arizona, Appellee v. Darren Lee Winegardner, Appellant.

Summary

The court held that a shoplifting conviction is not automatically admissible to impeach a witness under Arizona Rule of Evidence 609(a)(2). Admissibility depends on whether the court can readily determine from the conviction record that the offense involved a dishonest act or false statement, and the proponent bears the burden of making that showing without creating a trial within a trial. Because Winegardner provided no information establishing such a factual basis, the trial court did not abuse its discretion in excluding the conviction, and the court affirmed the conviction and sentence.