State of Arizona v. Bobby Ray Carter Jr

Summary

The court held that theft is a lesser-included offense of both vehicle theft and robbery, while vehicle theft is not a lesser-included offense of robbery. Applying the Blockburger same-elements test and examining legislative intent, it concluded that Carter could not receive multiple convictions and punishments for theft and vehicle theft or for theft and robbery arising from the same conduct, but could be punished separately for vehicle theft and robbery. The court affirmed the appellate decision and vacated Carter's theft conviction involving the SUV and vehicle-theft conviction involving the tractor.