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State v. Coddington
Citations: 662 P.2d 155; 135 Ariz. 480; 1983 Ariz. App. LEXIS 410Docket: 2 CA-CR 2656
Court: Court of Appeals of Arizona; February 28, 1983; Arizona; State Appellate Court
A jury convicted Craig Robert Coddington of obstructing criminal investigations or prosecutions, violating A.R.S. 13-2409, resulting in a presumptive two-year sentence. The statute defines the offense as knowingly attempting to obstruct communication of information related to criminal violations through bribery, misrepresentation, or intimidation. Coddington argued that the verdict forms did not align precisely with the statute, specifically contending that they required a finding of "material misrepresentation," while the statute used the term "misrepresentation" alone. The court found no prejudice in this additional requirement. He also claimed that the evidence was insufficient for conviction. The case stemmed from a plea agreement where Coddington was to provide information about a fellow serviceman, William Michael Miller, in exchange for leniency on a marijuana charge. During this time, Miller confided in Coddington about his involvement in burglaries and murders. However, during interviews, Coddington failed to disclose critical information regarding these crimes, only mentioning a false burglary report. After his arrest, he admitted to withholding knowledge of the burglaries and murders. Coddington contended that he was not specifically asked about these crimes and thus did not deny knowledge of them, asserting that his prosecution was based on omissions rather than statements. The court disagreed, clarifying that misrepresentation can include both the concealment of true information and false assertions, and that failing to disclose material facts can create a false impression. The court affirmed the conviction, concluding that Coddington's conduct violated the statute. The decision was unanimous among the judges.