State v. Turrubiates
In State v. Turrubiates, 25 Ariz. App. 234, 238, 542 P.2d 427, 431 (1975), the child victim died from a subdural hematoma that was the result of a skull fracture. 25 Ariz. App. at 237, 542 P.2d at 430.
An autopsy also revealed arm and rib fractures. Id.
The State presented expert testimony that substantial or severe force had to have been applied to the body in order to cause the skull fracture and that the force could not have resulted from the body falling or bumping an object. Id. at 237- 38, 542 P.2d at 430-31.
This testimony was introduced before any of the defendant's statements. Id.