## Facts

- David Wayne Grannis and Daniel Ethan Webster met in Phoenix in 1989 and later traveled together.
- While hitchhiking near Tucson on August 24, 1989, they were picked up by Richard, who invited them to stay the night at his home.
- Neighbors reported screaming from the home during the early morning hours; police found Richard dead in the hallway with multiple sharp-force and blunt-force injuries.
- The state charged both defendants with premeditated first-degree murder, two counts of theft, and trafficking in stolen property.
- At the joint jury trial, Webster did not testify; Grannis testified that Richard became sexually aggressive toward him, that Webster intervened, and that Grannis ran outside before the fatal attack occurred.
- The defendants left in Richard’s BMW and were later apprehended.
- The jury convicted both defendants of premeditated first-degree murder and the property offenses, and the trial court imposed death sentences after an aggravation/mitigation hearing.

## Issues

1. Whether admission of certain evidence in a joint trial of co-defendants with divergent defenses improperly prejudiced one or both defendants.
2. Whether the trial court’s evidentiary errors required reversal because they were not harmless beyond a reasonable doubt, particularly in a capital case.
3. Whether the joint-trial setting prevented the jury from reliably compartmentalizing evidence admissible against one defendant but prejudicial to the other.

## Decision

- The Arizona Supreme Court reversed the convictions of both defendants and remanded for retrial.
- The court held that the trial court improperly admitted certain evidence in the joint trial.
- The court concluded the resulting prejudice was not harmless beyond a reasonable doubt.
- Because the convictions were reversed, the death sentences were vacated.

## Legal Principles

- In a joint criminal trial, evidence admissible as to one defendant may require exclusion or other protection if its use in the joint setting unfairly prejudices a co-defendant.
- When evidentiary error occurs, the state must show beyond a reasonable doubt that the error did not contribute to the verdict to obtain affirmance on harmless-error grounds.
- In capital cases, appellate review applies especially close scrutiny to errors affecting the reliability of guilt determinations, including errors amplified by conflicting defenses and spillover prejudice in joint trials.

## Conclusion

The court ordered a new trial because improper evidentiary admissions in a joint capital prosecution created a risk of spillover prejudice that could not be deemed harmless beyond a reasonable doubt, undermining the reliability of the guilty verdicts.


State v. Grannis, 183 Ariz. 52, 900 P.2d 1 (Ariz. 1995)