A.R.S. 13-1802 Interpretation

In State v. Dixon, 127 Ariz. 554, 622 P.2d 501 (App. 1981), the Court relied on the tests suggested by the Washington Supreme Court in State v. Deffenbaugh, 216 Kan. 593, 533 P.2d 1328 (Wash. 1975), and determined that Arizona's theft statute, A.R.S. 13-1802, created a single offense that could be committed in different ways. The Court considered: (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,"; (4) whether those acts might "inhere in the same transaction." Dixon, 127 Ariz. at 561, 622 P.2d at 508.