State v. Valverde
In State v. Valverde, 220 Ariz. 582, P 12, 208 P.3d 233, 236 (2009), the Arizona Supreme Court explained the differences between structural error and fundamental error review. 220 Ariz. 582, PP 10, 12, 208 P.3d at 235-36.
Structural error involves a deprivation of a basic protection necessary for the trial to serve as a vehicle for determination of guilt or innocence. Id. P 10.
And if a reviewing court finds structural error has occurred, "prejudice is presumed." Id.
Fundamental error, on the other hand, requires a deprivation of a right essential to the defense and must be "'error of such magnitude the defendant could not have received a fair trial.'" Id. P 12, quoting State v. Henderson, 210 Ariz. 561, P 19, 115 P.3d 601, 607 (2005).
Unlike structural error in which prejudice is presumed, the defendant bears the burden of showing prejudice in a fundamental error analysis. Id.