In State v. Freeney, 223 Ariz. 110, 219 P.3d 1039, 1043 (Ariz. 2009) the Supreme Court of Arizona recognized that "a violation of one's statutorily provided right to a grand jury indictment does not necessarily equate to an infringement of a defendant's Sixth Amendment rights." The court found that "for Sixth Amendment purposes, courts look beyond the indictment to determine whether defendants received actual notice of charges, and the notice requirement can be satisfied even when a charge was not included in the indictment." Id.