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178 Ariz. 319

873 P.2d 657

149 Ariz.Adv.Rep. 22

State v. Varela

Court of Appeals of Arizona

Decided October 5, 1993

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Court of Appeals of Arizona · decided 1993-10-05

Cited by 20 later decisions — most recently September 2004

20 state decisions

Relies on State v. Spence

Good law ✅— No negative treatment on recordhow we know

Decided 1993-10-05

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GERBER, Judge,

¶1concurring.

¶2I write specially because I reach the same conclusion as the majority on the “prior bad act” issue but for a different reason. The stepdaughter’s testimony shows molestations almost continuously over an eight-year period prior to the acts charged here. Though these prior molestations go well beyond the three-year period in Treadaway, there really is no remoteness problem because essentially the same conduct spans the eight years up to the charged offenses. Apart from a short sojourn to Mexico, there never was a significant break in this pattern, which continued until the charged crimes occurred. Under this circumstance, no remoteness problem arises, no medical testimony was needed at all, and the entire span of prior acts was properly admitted. For similar facts, see State v. Spence, 146 Ariz. 142, 704 P.2d 272 (1985).

¶3Secondly, while I concur in the “similarity” conclusion, I do not agree that the act of writing the threatening letter of April 10, 1989 is similar to any act of molestation. Nor, in my view, is that narrow analysis of similarity of specific acts required or even possible. Rather, in a broader view, the similarity consists in the defendant’s common method of repeatedly using homicidal threats to induce his victims’ submission.

¶4While I concur completely with the majority’s analysis that Emerick was unqualified, it needs be underscored that no medical expert was necessary at all because the prior acts were both similar and proximate (because of continuity) to the charged acts, thus obviating in principle the need for the Treadaway approach.

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