State v. Smith
In State v. Smith, 113 Ariz. 298, 300, 552 P.2d 1192, 1194 (1976) the Arizona Supreme Court established a two-part test to determine if the evidence warrants a flight instruction.
First, "the evidence is viewed to ascertain whether it supports a reasonable inference that the flight or attempted flight was open, such as the result of an immediate pursuit." Id.
Second, if there is no open flight, "then the evidence must support the inference that the accused utilized the element of concealment or attempted concealment." Id.
"The absence of any evidence supporting either of these findings would mean that the giving of an instruction on flight would be prejudicial error." Id.