Sheehan v. Pima County
In Sheehan v. Pima County 135 Ariz. 235, 660 P.2d 486 (App. 1982), a wrongful death case, the court stated the general rule for considering a damages award allows a jury to consider the "decedent's characteristics and habits including his general ability, other occupations he was qualified to fulfill, his industriousness, disposition to earn, intelligence, manner of living, sobriety or intemperance, frugality or lavishness, and other personal characteristics that are of assistance in securing business or earning money." Id. at 239, 660 P.2d at 490.
The issue in Sheehan appears to concern economic loss, an issue the Ritchies abandoned to avoid opening the door for the admission of character evidence.
Because of this, the court applied Rules 403 and 404.