Ariz. Rev. Stat. » Title 13
Arizona Revised Statutes

Ariz. Rev. Stat. § 13-114 (2026)

Speedy trial; counsel; witnesses and confrontation

✓ current as of May 2026
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In a criminal action defendant is entitled:

1. To have a speedy public trial by an impartial jury of the county in which the offense is alleged to have been committed.

2. To have counsel.

3. To produce witnesses on his behalf, and to be confronted with the witnesses against him in the presence of the court, except that the testimony or deposition of a witness may be received in evidence at the trial as by law prescribed.

Notes of Decisions
Cited in 16 cases, 1985–2020 · leading case: State of Arizona v. Mark Goudeau, 372 P.3d 945 (Ariz. 2016).
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State of Arizona v. Mark Goudeau, 372 P.3d 945 (Ariz. 2016). · cites it 2× “Goudeau again affirmed that he would continue to work with his attorneys and did not expressly complain further about his counsel during the trial’s long guilt phase.”
State of Arizona v. Thomas Michael Riley, 459 P.3d 66 (Ariz. 2020). · cites it 2× “2, § 24; A.R.S. § 13-114(2); State v. LaGrand, 152 Ariz.”
State v. Cromwell, 119 P.3d 448 (Ariz. 2005). · cites it 2× “2, § 24; A.R.S. § 13-114(2) (2001); Ariz. R.Crim. P.”
State of Arizona v. Marcus Deshaun Tucker, Clifton James Cuttler II & Andre Lavelle Armstrong, 290 P.3d 1248 (Ariz. Ct. App. 2012). · cites it 2× “2d 675 (2010) (per curiam) (Sixth Amendment right to public trial applicable to states); see also A.R.S. § 13-114(1). 4 A “public trial” is “a trial which is open to the general public at all times.”
State v. Benenati, 52 P.3d 804 (Ariz. Ct. App. 2002). · cites it 2× “II, § 24; A.R.S. § 13-114; Ariz. R.Crim. P. 1.2, 7.”
State v. Moody, 968 P.2d 578 (Ariz. 1998). · cites it 2× “II, § 24; A.R.S. § 13-114(2); Ariz. R.Crim. P. 6.1.”
State v. Lehr, 38 P.3d 1172 (Ariz. 2002). “The defendant also asserted his confrontation right under article II, section 24 of the Arizona Constitution, and Arizona Revised Statutes section 13-114(3), but did not brief or argue this claim.”
United States v. Albert E. Mills. United States of Am. v. Kenneth B. Wonson, 964 F.2d 1186 (D.C. Cir. 1992). “Ariz.Rev.Stat.Ann. § 13-114 (1989) (for specific times see 17 A.”
Sa v. Superior Ct. in & for Cty. of Maricopa, 831 P.2d 1297 (Ariz. Ct. App. 1992). · cites it 2× “2d 59, 62 (1983); see also A.R.S. § 13-114(3) (defendant’s right to confront adverse witnesses at trial).”
State v. Bush, 714 P.2d 818 (Ariz. 1986). · cites it 2× “He maintains that the intimidation felt by his attorney caused him to give defendant deficient representation, and further that witnesses would not testify on his behalf out of fear for their own safety. The right to a fair trial, before an impartial jury, in a criminal…”
State of Arizona v. Demirus Ananda Koepke, 377 P.3d 385 (Ariz. Ct. App. 2016). · cites it 2× “II, §§ 4, 24; A.R.S. § 13-114(2); Ariz. R. Crim. P. 6.1.”
State v. Jones, 705 P.2d 955 (Ariz. Ct. App. 1985). · cites it 2× “The right to counsel is furthered by statute (A.R.S. § 13-114(2)) and court rule (Rule 6, Rules of Criminal Procedure, 17 A.”
Show all 16 citing cases →
— Ariz. Rev. Stat. § 13-114(1) — 2 cases
State of Arizona v. Marcus Deshaun Tucker, Clifton James Cuttler II & Andre Lavelle Armstrong, 290 P.3d 1248 (Ariz. Ct. App. 2012). “2d 675 (2010) (per curiam) (Sixth Amendment right to public trial applicable to states); see also A.R.S. § 13-114(1). 4 A “public trial” is “a trial which is open to the general public at all times.”
State of Arizona v. Hon. wein/goodman, 417 P.3d 787 (Ariz. 2018).
— Ariz. Rev. Stat. § 13-114(2) — 9 cases
State of Arizona v. Mark Goudeau, 372 P.3d 945 (Ariz. 2016). “Goudeau again affirmed that he would continue to work with his attorneys and did not expressly complain further about his counsel during the trial’s long guilt phase.”
State of Arizona v. Thomas Michael Riley, 459 P.3d 66 (Ariz. 2020). “2, § 24; A.R.S. § 13-114(2); State v. LaGrand, 152 Ariz.”
State v. Cromwell, 119 P.3d 448 (Ariz. 2005). “2, § 24; A.R.S. § 13-114(2) (2001); Ariz. R.Crim. P.”
State v. Moody, 968 P.2d 578 (Ariz. 1998). “II, § 24; A.R.S. § 13-114(2); Ariz. R.Crim. P. 6.1.”
State of Arizona v. Demirus Ananda Koepke, 377 P.3d 385 (Ariz. Ct. App. 2016). “II, §§ 4, 24; A.R.S. § 13-114(2); Ariz. R. Crim. P. 6.1.”
— Ariz. Rev. Stat. § 13-114(3) — 2 cases
State v. Lehr, 38 P.3d 1172 (Ariz. 2002). “The defendant also asserted his confrontation right under article II, section 24 of the Arizona Constitution, and Arizona Revised Statutes section 13-114(3), but did not brief or argue this claim.”
Sa v. Superior Ct. in & for Cty. of Maricopa, 831 P.2d 1297 (Ariz. Ct. App. 1992). “2d 59, 62 (1983); see also A.R.S. § 13-114(3) (defendant’s right to confront adverse witnesses at trial).”
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