State v. Steinle

¶ 18 I respectfully dissent from the majority’s holding that the trial court properly excluded the video under Arizona Rule of Evidence 106. Although Rule 106 properly applies to conduct, see, e.g., United States v. Spearman, 186 F.3d 743, 755 (6th Cir.1999) (applying the rule to a video demonstrating conduct); DesJardins v. State, 759 N.E.2d 1036, 1037 (Ind.2001) (same); Bunch v. State, 123 So.3d 484, 493-94 (Miss.2013) (same), the majority misapplies Rule 106 to *535preclude a complete statement that is otherwise admissible. Given the explosive growth of social networking and the constant…