lesser standard (Arizona) · Go Syfert
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lesser standard in Arizona

29 Arizona opinions name it 2 courts 1977–2026 6 in the last five years

The cases below were cited by Arizona courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (19)

CaseFollowedCited
Rainwater v. Rainwatergreen
arizctapp · 1993 · cited in 2 Arizona opinions naming this issue, 2014–2023
2 sentences

2023On the contrary, courts have long recognized that “divorce often requires a lesser standard of living for both parties.” Rainwater v. Rainwater, 177 Ariz. 500, 504 (App. 1993).

2014To the contrary, and as we have said on another occasion, “divorce often requires a lesser standard of living for both parties.” Rainwater v. Rainwater, 177 Ariz. 500, 504 , 869 P.2d 176, 180 (App. 1993). ¶8 Wife contends that the court failed to consider that Husband earned more than $170,000 annually, they enjoyed a comfortable lifestyle, and they accumulated no debt.

22
State of Arizona v. David James Yonkmangreen
arizctapp · 2013 · cited in 2 Arizona opinions naming this issue, 2020–2021
2 sentences

2021Cf. State v. Yonkman, 233 Ariz. 369, 374, ¶ 15 (App. 2013). ¶14 Based on this evidence, a reasonable juror could infer that Reed promoted or facilitated the August 2016 transaction or provided the means for its occurrence.

2020Collateral estoppel requires that the “issue sought to be relitigated must be precisely the same as the issue in the previous litigation.” State v. Jimenez, 130 Ariz. 138, 140 (1981). ¶20 The collateral estoppel component of double jeopardy does not prohibit the State “from relitigating an issue when it is presented in a subsequent action governed by a lower standard of proof.” Dowling v. United States, 493 U.S. 342, 349 (1990); see also State v. Lehr, 227 Ariz. 140, 148, ¶ 26 (2011) (“[A]dmission of evidence of other acts for which a defendant has been acquitted does not violate double jeopar

22
Dowling v. United Statesgreen
scotus · 1990 · cited in 2 Arizona opinions naming this issue, 2013–2020
2 sentences

2020Collateral estoppel requires that the “issue sought to be relitigated must be precisely the same as the issue in the previous litigation.” State v. Jimenez, 130 Ariz. 138, 140 (1981). ¶20 The collateral estoppel component of double jeopardy does not prohibit the State “from relitigating an issue when it is presented in a subsequent action governed by a lower standard of proof.” Dowling v. United States, 493 U.S. 342, 349 (1990); see also State v. Lehr, 227 Ariz. 140, 148, ¶ 26 (2011) (“[A]dmission of evidence of other acts for which a defendant has been acquitted does not violate double jeopar

2013As the Supreme Court established in Dowling v. United States, the admission of testimony about acquitted conduct is not barred categorically by the Double Jeopardy Clause or the Due Process Clause of the United States Constitution when such evidence is governed by a lesser standard than proof beyond a reasonable doubt. 493 U.S. 342, 343-44, 348 , 110 S.Ct. 668 , 107 L.Ed.2d 708 (1990).

22
State v. Moodygreen
ariz · 2004 · cited in 2 Arizona opinions naming this issue, 2024–2026
2 sentences

2026Cf. State v. Snelling, 225 Ariz. 182, 186 ¶ 12 (2010) (stating that “a conviction precludes review of the finding of probable cause made by a grand jury” (quoting State v. Moody, 208 Ariz. 424, 440 n.3 ¶ 31 (2004))); A.R.S. § 13-202(C) (providing that proof of a greater culpable mental state establishes proof of a lesser culpable mental state).

2024See Muhammad, 253 Ariz. at 381, ¶ 44 ("Where 'a defendant has already been adjudicated competent, the court must be permitted to rely on the record supporting that previous adjudication.'" (quoting State v. Moody, 208 Ariz. 424, 443, ¶ 48 (2004))); Bishop, 162 Ariz. at 105 (according "some evidentiary weight" to an earlier finding, under "a lesser standard," that the defendant was competent to assist his counsel). ¶27 Second, plea counsel agreed to a competency determination based on Dr. Hurley's report and did not seek to have Sills re-evaluated before he was sentenced.

12
State v. Piercegreen
arizctapp · 1977 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See State v. Lopez, 110 Ariz. 198, 199 (1973) (finding no due process violation in the determination of the defendant's competence to plead guilty where the competency proceedings complied with statutory requirements and defense counsel agreed to a determination 8 STATE v. SILLS Decision of the Court based on written reports of psychiatrists); State v. Pierce, 116 Ariz. 435, 43839 (App. 1977) ("[U]nless counsel has indicated a contrary view on the record, the offering by an accused client of a plea of guilty should logically constitute a representation on the part of defense counsel that at le

11
State v. Lopezgreen
ariz · 1973 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See State v. Lopez, 110 Ariz. 198, 199 (1973) (finding no due process violation in the determination of the defendant's competence to plead guilty where the competency proceedings complied with statutory requirements and defense counsel agreed to a determination 8 STATE v. SILLS Decision of the Court based on written reports of psychiatrists); State v. Pierce, 116 Ariz. 435, 43839 (App. 1977) ("[U]nless counsel has indicated a contrary view on the record, the offering by an accused client of a plea of guilty should logically constitute a representation on the part of defense counsel that at le

11
State v. Bishopgreen
ariz · 1989 · cited in 1 Arizona opinions naming this issue, 2024–2024
1 sentence

2024See Muhammad, 253 Ariz. at 381, ¶ 44 ("Where 'a defendant has already been adjudicated competent, the court must be permitted to rely on the record supporting that previous adjudication.'" (quoting State v. Moody, 208 Ariz. 424, 443, ¶ 48 (2004))); Bishop, 162 Ariz. at 105 (according "some evidentiary weight" to an earlier finding, under "a lesser standard," that the defendant was competent to assist his counsel). ¶27 Second, plea counsel agreed to a competency determination based on Dr. Hurley's report and did not seek to have Sills re-evaluated before he was sentenced.

11
People v. Banksgreen
cal · 2015 · cited in 1 Arizona opinions naming this issue, 2022–2022
1 sentence

2022See People v. Banks, 351 P.3d 330, 338 (Cal. 2015) (“The defendants’ actions in [Tison] and [Enmund] represent points on a continuum.

11
State v. Lehrgreen
ariz · 2011 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020Collateral estoppel requires that the “issue sought to be relitigated must be precisely the same as the issue in the previous litigation.” State v. Jimenez, 130 Ariz. 138, 140 (1981). ¶20 The collateral estoppel component of double jeopardy does not prohibit the State “from relitigating an issue when it is presented in a subsequent action governed by a lower standard of proof.” Dowling v. United States, 493 U.S. 342, 349 (1990); see also State v. Lehr, 227 Ariz. 140, 148, ¶ 26 (2011) (“[A]dmission of evidence of other acts for which a defendant has been acquitted does not violate double jeopar

11
State v. Jimenezgreen
ariz · 1981 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020Collateral estoppel requires that the “issue sought to be relitigated must be precisely the same as the issue in the previous litigation.” State v. Jimenez, 130 Ariz. 138, 140 (1981). ¶20 The collateral estoppel component of double jeopardy does not prohibit the State “from relitigating an issue when it is presented in a subsequent action governed by a lower standard of proof.” Dowling v. United States, 493 U.S. 342, 349 (1990); see also State v. Lehr, 227 Ariz. 140, 148, ¶ 26 (2011) (“[A]dmission of evidence of other acts for which a defendant has been acquitted does not violate double jeopar

11
State v. Bennettgreen
ariz · 2006 · cited in 1 Arizona opinions naming this issue, 2017–2017
1 sentence

2017P. 32.2(a); see State v. Bennett, 213 Ariz. 562, 566 , 2 Luke asserts that, as a self-represented petitioner, he is entitled to be held to a lesser standard than a lawyer.

11
State v. Cornellgreen
ariz · 1994 · cited in 1 Arizona opinions naming this issue, 2017–2017
1 sentence

2017Cf. State v. Cornell, 179 Ariz. 314, 331 (1994) (“[A] defendant acting in propria persona is subject to the same rules as an attorney.”). ¶10 Hazzard’s reliance on Smith also is misplaced.

11
In Re Twenty-Four ThouSand Dollars ($24,000) in United States Currencygreen
arizctapp · 2007 · cited in 1 Arizona opinions naming this issue, 2016–2016
1 sentence

2016See In re $24,000.00 in U.S. Currency, 217 Ariz. 199, 202, ¶ 8 (App. 2007).

11
Hasten v. Stategreen
ariz · 1929 · cited in 1 Arizona opinions naming this issue, 2014–2014
2 sentences

2014See Hasten v. State, 35 Ariz. 427, 430-31 , 280 P. 670, 671 (1929) (noting that a 1927 statutory change from penalizing driving by someone who “becomes or is intoxicated” to penalizing driving by someone who is “under the influence of intoxicating liquor” evidenced the Legislature’s decision that “many persons who ha[ve] not yet arrived at [the point of actual intoxication]” should nevertheless be prohibited from driving); see also State v. Noble, 119 Or. 674 , 250 P. 833, 834 (1926) (concluding that the “under the influence of intoxicating liquor” standard under Oregon law was a lesser standa

2014See Hasten v. State, 35 Ariz. 427, 430-31 , 280 P. 670, 671 (1929) (noting that a 1927 statutory change from penalizing driving by someone who “becomes or is intoxicated” to penalizing driving by someone who is “under the influence of intoxicating liquor” evidenced the Legislature’s decision that “many persons who ha[ve] not yet arrived at [the point of actual intoxication]” should nevertheless be prohibited from driving); see also State v. Noble, 119 Or. 674 , 250 P. 833, 834 (1926) (concluding that the “under the influence of intoxicating liquor” standard under Oregon law was a lesser standa

11
State v. Noblegreen
or · 1926 · cited in 1 Arizona opinions naming this issue, 2014–2014
2 sentences

2014See Hasten v. State, 35 Ariz. 427, 430-31 , 280 P. 670, 671 (1929) (noting that a 1927 statutory change from penalizing driving by someone who “becomes or is intoxicated” to penalizing driving by someone who is “under the influence of intoxicating liquor” evidenced the Legislature’s decision that “many persons who ha[ve] not yet arrived at [the point of actual intoxication]” should nevertheless be prohibited from driving); see also State v. Noble, 119 Or. 674 , 250 P. 833, 834 (1926) (concluding that the “under the influence of intoxicating liquor” standard under Oregon law was a lesser standa

2014See Hasten v. State, 35 Ariz. 427, 430-31 , 280 P. 670, 671 (1929) (noting that a 1927 statutory change from penalizing driving by someone who “becomes or is intoxicated” to penalizing driving by someone who is “under the influence of intoxicating liquor” evidenced the Legislature’s decision that “many persons who ha[ve] not yet arrived at [the point of actual intoxication]” should nevertheless be prohibited from driving); see also State v. Noble, 119 Or. 674 , 250 P. 833, 834 (1926) (concluding that the “under the influence of intoxicating liquor” standard under Oregon law was a lesser standa

11
State v. Sierra-Cervantesgreen
arizctapp · 2002 · cited in 1 Arizona opinions naming this issue, 2008–2008
2 sentences

2008State v. Sierra-Cervantes, 201 Ariz. 459, 464, ¶ 29 , 37 P.3d 432, 437 (App.2001).

2008State v. Sierra-Cervantes, 201 Ariz. 459, 464, ¶ 29 , 37 P.3d 432, 437 (App.2001).

11
United States v. $191,910.00 in U.S. Currency, Bruce R. Morgan, Claimant-Appelleegreen
ca9 · 1994 · cited in 1 Arizona opinions naming this issue, 1994–1994
1 sentence

1994See, e.g., United States v. $191,910 in United States Currency, 16 F.3d 1051, 1069 (9th Cir.1994) (disparity between government’s and claimant’s burdens “involves a serious risk that an innocent person will be deprived of his property”).

11
State v. Decellogreen
ariz · 1974 · cited in 1 Arizona opinions naming this issue, 1989–1989
11
Hunt Building Corp. v. Industrial Commissiongreen
arizctapp · 1985 · cited in 1 Arizona opinions naming this issue, 1986–1986
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (21)

CaseCitedYears
Valerie M. v. Arizona Department of Economic Security green
arizctapp · 2008
2 sentences

2009Id. at 159 ¶ 14, 195 P.3d at 196 .

2009Id. at 159 ¶ 14, 195 P.3d at 196 .

22009–2009
State v. Snelling green
ariz · 2010
1 sentence

2026Cf. State v. Snelling, 225 Ariz. 182, 186 ¶ 12 (2010) (stating that “a conviction precludes review of the finding of probable cause made by a grand jury” (quoting State v. Moody, 208 Ariz. 424, 440 n.3 ¶ 31 (2004))); A.R.S. § 13-202(C) (providing that proof of a greater culpable mental state establishes proof of a lesser culpable mental state).

12026–2026
Harris v. Coleman green
nysd · 2012
1 sentence

2024Their fraudulent assignment therefore can support a conversion claim, Harris v. Coleman, 863 F.Supp. 2d 336 , 344–45 (S.D.N.Y. 2012), and, logically, the lesser claim of trespass to chattel. ¶41 We hold that in the modern digitized world, electronic touching may suffice.

12024–2024
State v. Terrazas green
ariz · 1997
2 sentences

2013In accord with those cases, we conclude an acquittal does not bar the introduction of other-act evidence under Rule 404, because such evidence involves a lesser standard of proof, and “the earlier acquittal could be based upon the failure of the state to have proved the prior bad acts beyond a reasonable doubt.” Terrazas, 189 Ariz. at 584 n. 3, 944 P.2d at 1198 n. 3. ¶ 16 As noted, Yonkman does not challenge the admission of the evidence on the ground the trial court incorrectly applied Rule 404(b) and (c).

2013In accord with those cases, we conclude an acquittal does not bar the introduction of other-act evidence under Rule 404, because such evidence involves a lesser standard of proof, and “the earlier acquittal could be based upon the failure of the state to have proved the prior bad acts beyond a reasonable doubt.” Terrazas, 189 Ariz. at 584 n. 3, 944 P.2d at 1198 n. 3. ¶ 16 As noted, Yonkman does not challenge the admission of the evidence on the ground the trial court incorrectly applied Rule 404(b) and (c).

12013–2013
Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah green
scotus · 1993
1 sentence

2009Such laws are subject to strict scrutiny and survive such searching review “only in rare eases.” Id. ¶ 16 In contrast to the targeted law at issue in Dukumi Babalu Aye, laws of general applicability are judged under the First Amendment by a lesser standard.

12009–2009
Wisconsin v. Yoder green
scotus · 1972
2 sentences

2009In Yoder , the Court acknowledged that religiously based conduct is “often subject to regulation by the States in the exercise of their undoubted power to promote the health, safety, and general welfare, or the Federal Government in the exercise of its delegated powers.” 406 U.S. at 220 , 92 S.Ct. 1526 .

2009In Yoder , the Court acknowledged that religiously based conduct is “often subject to regulation by the States in the exercise of their undoubted power to promote the health, safety, and general welfare, or the Federal Government in the exercise of its delegated powers.” 406 U.S. at 220 , 92 S.Ct. 1526 .

12009–2009
People v. Ray green
cal · 1999
2 sentences

2007The court noted that "the appropriate standard under the community caretaker exception is one of reasonableness: Given the known facts, would a prudent and reasonable officer have perceived a need to act in the proper discharge of his or her community caretaking functions?" Id. at 476-77 , 88 Cal.Rptr.2d 1 , 981 P.2d at 937 . ¶ 53 On the facts in the case at hand, my view is that the standard from Fisher for emergency aid has been met.

2007The court noted that "the appropriate standard under the community caretaker exception is one of reasonableness: Given the known facts, would a prudent and reasonable officer have perceived a need to act in the proper discharge of his or her community caretaking functions?" Id. at 476-77 , 88 Cal.Rptr.2d 1 , 981 P.2d at 937 . ¶ 53 On the facts in the case at hand, my view is that the standard from Fisher for emergency aid has been met.

12007–2007
Apprendi v. New Jersey green
scotus · 2000
1 sentence

2004The Cou rt reasoned in Apprendi that “there is a vast difference between accepting the validity of a prior judgment of convictio n entered in a proceed ing in which the defendan t had the righ t to a jury 3 In Blakely v. Washington, No. 02-1632, 2004 WL 1402697 (U.S. June 24, 2004), the Supreme Court’s most recent decision dealing with the Apprendi doctrine, the Court left unchanged that portion of Apprendi excepting the fact of a prior conviction from the rule that a jury must find certain facts that affect the length of a sentence. 9 trial and the right to require the prosecutor to prove gui

12004–2004
Claude Cauley v. United States green
ca5 · 1966
2 sentences

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. 7 See, e.g., Cauley v. United States, 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. [7] See, e.g., Cauley v. United States, *538 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

11995–1995
Theodore v. Alaska green
scotus · 1966
2 sentences

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. 7 See, e.g., Cauley v. United States, 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. [7] See, e.g., Cauley v. United States, *538 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

11995–1995
Hexagon Laboratories, Inc. v. United States green
scotus · 1966
2 sentences

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. 7 See, e.g., Cauley v. United States, 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. [7] See, e.g., Cauley v. United States, *538 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

11995–1995
Cook Electric Co. v. Frank Horton & Co. green
scotus · 1966
2 sentences

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. 7 See, e.g., Cauley v. United States, 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

1995A lesser standard has been allowed in cases in which the question of territorial jurisdiction is identified with the issue of venue. [7] See, e.g., Cauley v. United States, *538 355 F.2d 175 (5th Cir.), cert. denied, 384 U.S. 951 , 86 S.Ct. 1572 , 16 L.Ed.2d 548 (1966).

11995–1995
Matter of Hendrix green
ariz · 1985
2 sentences

1994Despite the fact that the judge in that case had *114 used her office to obtain special privileges and favors for her clerk, the court agreed that her actions did not constitute "willful conduct in office," but only "violated the lesser standard of `conduct prejudicial to the administration of justice that brings the judicial office into disrepute.'" Id. at 348-49 , 701 P.2d at 844-45 .

1994Despite the fact that the judge in that case had *114 used her office to obtain special privileges and favors for her clerk, the court agreed that her actions did not constitute "willful conduct in office," but only "violated the lesser standard of `conduct prejudicial to the administration of justice that brings the judicial office into disrepute.'" Id. at 348-49 , 701 P.2d at 844-45 .

11994–1994
State v. Callahan green
arizctapp · 1978
11993–1993
State v. Marchesano green
arizctapp · 1989
11990–1990
Quadrini v. Sikorsky Aircraft Division green
ctd · 1977
11988–1988
ILC Peripherals Leasing Corp. v. International Business Machines Corp. green
cand · 1977
11988–1988
State v. Young green
ohio · 1980
11988–1988
Holloway v. Florida green
scotus · 1980
11988–1988
Brower's Moving & Storage, Inc. v. National Labor Relations Board green
scotus · 1991
11988–1988
State v. Schantz green
ariz · 1965
11977–1977

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-120.24 (4) AZ § Ariz. Rev. Stat. § 13-1003 (3) AZ § Ariz. Rev. Stat. § 13-1105 (3) AZ § Ariz. Rev. Stat. § 13-4031 (3) AZ § Ariz. Rev. Stat. § 13-703 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 182 (1906–2026) TX 127 (1970–2026) OH 118 (1973–2025) NY 114 (1933–2026) IL 112 (1962–2025) PA 101 (1974–2026) IN 75 (1974–2026) LA 70 (1967–2025) FL 69 (1974–2025) WA 55 (1980–2026) CT 51 (1976–2024) MI 48 (1979–2026) GA 42 (1924–2023) NJ 41 (1953–2026) MD 41 (1975–2026) DC 34 (1970–2024) MA 33 (1966–2025) VA 31 (1982–2024) AZ 29 (1977–2026) KS 27 (1977–2026) AL 22 (1979–2024) TN 21 (1989–2026) OR 20 (1969–2023) CO 19 (1979–2026) WI 18 (1925–2023) NM 17 (1975–2017) MN 17 (1980–2014) OK 17 (1962–2022) MO 16 (1987–2020) MS 16 (1987–2025) IA 15 (1974–2022) NC 14 (1958–2026) KY 13 (1964–2024) AR 12 (1983–2023) ID 12 (1980–2014) WV 12 (1979–2022) AK 12 (1977–2017) VT 12 (1975–2020) MT 11 (2005–2026) RI 11 (1983–2011) SC 10 (1989–2020) NE 10 (1982–2023) UT 9 (1929–2024) DE 9 (1973–2026) ND 9 (1990–2016) WY 9 (1990–2022) SD 6 (1979–2008) ME 6 (1981–2018) NH 6 (1980–2019) HI 5 (1984–2007) NV 5 (1997–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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