State v. Smith (1985)

In State v. Smith, 146 Ariz. 491, 498-99, 707 P.2d 289, 296-97 (1985) the court determined that a guilty verdict for armed robbery necessarily includes a jury finding that the offense was dangerous because armed robbery can only be committed when one uses a "deadly weapon" or "dangerous instrument." "Thus, no specific finding of dangerousness is required where an element of the offense charged requires proof of the dangerous nature of the felony." Id. at 499, 707 P.2d at 297 .