## Facts

- William Joseph Reagan, Jr. was charged with manslaughter arising from a high-speed collision that killed another driver.
- Reagan claimed he was involved in a “road rage” incident and believed occupants of another truck threatened him and his brother with serious harm.
- Reagan asserted he attempted to leave but was chased and, out of fear, drove quickly to escape perceived danger.
- Witnesses reported another truck either racing with or chasing Reagan’s vehicle.
- Reagan drove about 79–84 mph in a 40 mph zone, ran a red light, and struck the victim’s car, causing her death.
- Reagan’s blood alcohol concentration was 0.093.
- The State moved in limine to preclude evidence of the alleged chase and threats, arguing justification statutes barred such evidence because Reagan’s intoxicated, reckless driving could not be justified.
- The superior court denied the motion and allowed Reagan to present the chase/threat evidence.
- The State sought special action relief because it lacked a statutory right to appeal the denial of its pretrial evidentiary motion.

## Issues

1. Whether the State lacked an adequate remedy by appeal such that special action jurisdiction was appropriate to review an order denying the State’s motion to preclude evidence.
2. Whether facts resembling “justification” evidence, barred as the basis for a statutory justification defense under A.R.S. §§ 13-401(A), 13-412(C), and 13-417(C), may nevertheless be admitted for a separate, relevant purpose—specifically, to rebut or mitigate proof of the culpable mental state (recklessness) required for manslaughter.

## Decision

- The court of appeals accepted special action jurisdiction because the State had no adequate remedy by appeal and the issue presented a purely legal question of statewide importance.
- The court denied relief, leaving in place the trial court’s ruling permitting Reagan to introduce evidence of threats and pursuit.
- The court held the trial court did not err in admitting the evidence when offered to address Reagan’s mental state (recklessness), not to establish a statutory justification defense.
- The court noted trial courts may admit evidence for a proper purpose even if it would be improper for another purpose, and may use limiting instructions to restrict its use.

## Legal Principles

- Special action jurisdiction may be appropriate when no adequate remedy by appeal exists and the petition presents an important legal question; the State generally cannot appeal an order denying a motion to suppress or preclude evidence under A.R.S. § 13-4032.
- Statutes limiting or barring a defendant’s ability to assert a substantive justification defense do not automatically create a categorical rule excluding related facts for all purposes.
- Evidence may be inadmissible for one purpose yet admissible for another relevant purpose; admissibility turns on the purpose for which the evidence is offered and its relevance to a material issue.
- In a manslaughter prosecution requiring proof of recklessness, evidence bearing on the defendant’s perception of danger and resulting conduct may be relevant to whether the defendant acted with the required culpable mental state.
- Trial courts have discretion to admit relevant evidence subject to safeguards, including limiting instructions, to prevent the jury from treating the evidence as establishing a prohibited justification defense.

## Conclusion

The court permitted the defendant to present evidence of threats and pursuit not as legal justification for intoxicated, high-speed driving, but as relevant evidence bearing on whether the State proved the mens rea of recklessness for manslaughter; the State’s requested extraordinary relief was denied.


State ex rel. Thomas v. Duncan, 216 Ariz. 260, 165 P.3d 238 (Ariz. Ct. App. 2007)