State v. Holm

OPINION

HOWARD, Judge.

¶ 1 Appellant was tried in absentia and found guilty by a jury of one count of possession of drug paraphernalia with one prior conviction. He was sentenced to a presumptive prison term of 1.75 years. He raises three issues on appeal, none of which merits reversal.

TRIAL IN ABSENTIA

¶2 First, appellant argues that the trial court violated his due process rights by holding the trial in his absence. A criminal defendant has a right to be present at any proceeding, but may waive that right by “voluntarily absenting himself ... from it.” Ariz. R.Crim. P. 9.1, 17 A.R.S. “ ‘The…