State v. Jones
Annotate this CaseThe Supreme Court granted review in this case to resolve the conflict between Ariz. Rev. Stat. 13-116, which requires that concurrent sentences be imposed on a defendant whose convictions stem from a single act, and Ariz. Rev. Stat. 13-705(M), which requires that sentences imposed on a defendant convicted of certain dangerous crimes against children run consecutively even when the underlying convictions arise from a single act. Defendant was convicted of reckless child abuse (Count 1), child abuse (Count 2), and first degree murder (Count 3). The trial court convicted her to terms of imprisonment on all counts, with Count 2 to be served consecutively to the other sentences. The court of appeals affirmed the convictions but modified the sentence to make Count 2 concurrent, rather than consecutive, to the other sentences. The Supreme Court vacated the court of appeals’ opinion and affirmed the judgment of the trial court, holding (1) under the rule that when statutes conflict and cannot be harmonized, the more recent statute applies, section 13-705(M) should govern in this case because it is more recent; and (2) therefore, the trial court properly ordered Defendant’s sentence on Count 2 to be served consecutively to her other sentences.
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