Alternative Means of Committing the Same Offense In Arizona

In determining whether a statute provides alternative means of committing the same offense, we must "ascertain and give effect to the intent of our legislature." State v. Garcia, 219 Ariz. 104,6, 193 P.3d 798, 800 (App. 2008); see also State v. Manzanedo, 210 Ariz. 292,8, 110 P.3d 1026, 1028 (App. 2005). In conducting this analysis, we may consider: "(1) the title of the statute; (2) whether there was 'a readily perceivable connection between the various acts' listed in the statute; (3) whether those acts were 'consistent with and not repugnant to each other,' and; (4) whether those acts might 'inhere in the same transaction.'" Manzanedo, 210 Ariz. 292,8, 110 P.3d at 1028, quoting State v. Dixon, 127 Ariz. 554, 561, 622 P.2d 501, 508 (App. 1980). The plain language of a statute is the best and most reliable indicator of the legislature's intent. State v. Christian, 202 Ariz. 462,5, 47 P.3d 666, 667-68 (App. 2002). "'When a statute is clear and unambiguous, we apply its plain language and need not engage in any other means of statutory interpretation.'" State v. Gongora, 235 Ariz. 178,5, 330 P.3d 368, 369 (App. 2014), quoting State v. Arellano, 213 Ariz. 474,9, 143 P.3d 1015, 1018 (2006).