State v. Martin

In State v. Martin, 105 Ariz. 265, 266, 463 P.2d 63, 64 (1970) the Arizona Supreme Court concluded that a phrase in a former drug statute, prohibiting the "furnishing" or "sale" of marijuana, merely stated "one crime, which may be committed in several different ways." And in State v. Dixon, the Court reached a similar conclusion with regard to a theft statute, resolving the question of legislative intent by inquiring whether: (1) the acts at issue had a common object; (2) they were "consistent with and not repugnant to each other" (in other words, whether proof of one would disprove another), and; (3) they might "inhere in the same transaction." 127 Ariz. at 561, 622 P.2d at 508.