State of Arizona v. Manuel David Perez-Gutierrez

Summary

The court held that a sentencing court's failure to state on the record its reasons for imposing consecutive or concurrent sentences violates the statutory requirement but is neither structural error nor ordinary trial error. Because the violation concerns an administrative duty that does not affect the sentence's reliability or outcome, the proper remedy is a limited remand for the trial court to state its reasons, without resentencing or vacating the sentence. The court vacated the court of appeals' decision and remanded with detailed time limits and briefing instructions.