State v. Bishop
In State v. Bishop, 144 Ariz. 521, 524, 698 P.2d 1240, 1243 (1985), the defendant had argued in his petition that it was possible jurors had relied on different underlying felonies to convict him of felony murder, rendering his conviction invalid for lack of jury unanimity. Bishop, 144 Ariz. at 523, 698 P.2d at 1242.
The defendant in Bishop apparently filed a supplemental reply brief in which he had argued "evidence was introduced at trial to support a finding of kidnapping by the jury as an underlying felony."
The court, in its discretion, considered the argument. Id. at 524, 698 P.2d at 1243.