State v. Miller

OPINION

HOWARD, Judge.

Appellant was convicted by a jury of fourth-degree arson, A.R.S. Sec. 13-234, and was placed on probation for a period of two years. He contends that the trial court erred in granting the state’s motion in limine, refusing certain instructions and admitting into evidence a spontaneous statement uttered by him on the way to the police station.

Resolution of the questions presented for review depends upon the answers to two questions. (1) Is fourth-degree arson a specific intent crime? (2) Is a spontaneous statement by a person too intoxicated to waive his Miranda rights…