State v. Manseau

CourtCourt of Appeals of Arizona
DecidedApril 17, 2026
Docket1 CA-CR 25-0026
StatusUnpublished
AuthorJames B. Morse, Jr.

This text of State v. Manseau (State v. Manseau) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Manseau, (Ark. Ct. App. 2026).

Opinion

NOTICE: NOT FOR OFFICIAL PUBLICATION. UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

STATE OF ARIZONA, Appellee,

v.

BRADLEY JAMES MANSEAU, Appellant.

No. 1 CA-CR 25-0026 FILED 04-17-2026

Appeal from the Superior Court in Maricopa County No. S8015CR202400095 The Honorable Derek C. Carlisle, Judge

AFFIRMED

COUNSEL

Arizona Attorney General's Office, Phoenix By Rebecca Jones Counsel for Appellee

Carr Law Office, PLLC, Kingman By Sandra Carr Counsel for Appellant STATE v. MANSEAU Decision of the Court

MEMORANDUM DECISION

Judge James B. Morse Jr. delivered the decision of the Court, in which Presiding Judge Andew M. Jacobs and Judge Brian Y. Furuya joined.

M O R S E, Judge:

¶1 Bradley James Manseau appeals his conviction and sentences for three counts of sexual conduct with a minor and one count of attempted sexual conduct with a minor. For the reasons set forth below, we affirm.

FACTS AND PROCEDURAL BACKGROUND

¶2 Manseau's daughter Emmy (a pseudonym) accused him of sexually abusing her between the ages of four and eleven. Manseau did not always live with Emmy and served time in jail between April 2018 and October 2020. In 2024, the State indicted Manseau on three counts of sexual conduct with a minor and one count of attempted sexual conduct with a minor. The State alleged the crimes occurred between 2015 and 2021.

¶3 Trial was delayed twice. First, the State requested a continuance because a key witness, the investigating detective, was not available on the original trial dates. The State moved to continue but was also willing to accelerate trial. Manseau objected to a continuance, but Manseau's counsel was unavailable for an earlier date and expressed a preference for a later date. The court granted the continuance and delayed trial by two weeks.

¶4 The second delay occurred when the State interviewed Emmy the day before trial. Immediately following the interview, the State disclosed that she had made new abuse allegations against Manseau. The State also disclosed that another alleged Manseau victim, herself a potential Arizona Rule of Evidence ("Rule") 404(c) witness in this case, had recently made unsubstantiated allegations of sexual abuse against a third party not involved in this case (her stepfather). Manseau moved to dismiss the indictment with prejudice, alleging the State violated its Brady obligation by intentionally withholding exculpatory evidence, putting him in the untenable position of choosing between a speedy trial or effective assistance of counsel. The superior court denied the motion, instead granting the State's request to preclude evidence of the new allegations. The court also

2 STATE v. MANSEAU Decision of the Court

offered to preclude the Rule 404(c) witness altogether, but Manseau disagreed because he wanted to explore using that witness's testimony to impeach Emmy. Ultimately, Manseau requested a continuance.

¶5 At trial, Emmy, then thirteen, testified to the specifics of the abuse, but had trouble remembering specific dates and prior statements. For example, she testified Manseau had attempted to abuse her in a car in 2022, even though she previously claimed it occurred in 2020. Investigating detectives also testified on a variety of topics, including discovery of recent Google searches on Manseau's phone at the time of his arrest. Manseau attempted to impeach Emmy with an alleged prior statement in which she said the abuse was a dream. Emmy disagreed that she had called the abuse a dream, and another testifying detective said he did not recall Emmy making that statement.

¶6 The State also introduced a portion of Manseau's Google search history as aberrant-sexual propensity evidence. The court had found the evidence admissible under Rule 404(c) at a pre-trial hearing. During trial, the State attempted to impeach Manseau's brother about drug use. The brother denied drug use, stating he only had a slight addiction to energy drinks. Finally, during closing arguments, the prosecutor referred to Emmy's alleged "dream" statement as "false information" and used Ted Bundy as an example of an outwardly likable individual that no one expected to commit heinous crimes.

¶7 The jury returned a guilty verdict on all four counts, and found an aggravator because Emmy suffered emotional harm. The court sentenced Manseau to life in prison on count 1, consecutive 20-year prison sentences on counts 2 and 3, and a consecutive 10-year prison sentence on count 4. Manseau timely appealed and we have jurisdiction under A.R.S. §§ 12-120.21(A)(1), 13-4031, and -4033(A).

DISCUSSION

¶8 Manseau raises many issues on appeal. We address them below, reviewing the facts in the light most favorable to sustaining the verdict and resolving all reasonable inferences against Manseau. State v. Castaneda, 254 Ariz. 9, 11, ¶ 2 (App. 2022).

I. Emmy's Competency.

¶9 Manseau argues the court should have sua sponte ordered a competency hearing because Emmy's trial testimony was inconsistent and she made factually impossible claims.

3 STATE v. MANSEAU Decision of the Court

¶10 Because Manseau failed to object on competency grounds or request a competency hearing, we only review for fundamental error. State v. Escalante, 245 Ariz. 135, 140, ¶ 12 (2018). Manseau must prove an error occurred, and that the error was fundamental, i.e., it (1) went to the foundation of the case, (2) took away a right essential to the defense, or (3) was so egregious it made it impossible to have a fair trial. Id. at 142, ¶ 21. If Manseau proves the first or second option of prong two, he must also prove he suffered a non-speculative prejudice. See State v. Munninger, 213 Ariz. 393, 397, ¶ 14 (App. 2006).

¶11 Emmy was thirteen when she testified. Everyone is presumed competent to testify unless the rules of evidence or applicable statutes direct otherwise. Ariz. R. Evid. 601; see also, A.R.S. § 13-4061 ("In a criminal trial every person is competent to be a witness."). "Neither age, mental capacity nor feeble-mindedness renders a witness incompetent or disqualified." Castaneda, 254 Ariz. at 12, ¶ 16 (cleaned up). A trial court has no independent duty to examine the competency of a child over ten years old. State v. Perez, 109 Ariz 572, 574 (1973). The trial court has broad discretion to determine the need for a competency hearing to inquire into the witness's capacity to perceive, recollect, or communicate about the events in question. State v. Strong, 258 Ariz. 184, 203, ¶ 69 (2024). Notably, competency and credibility are distinct inquiries, the latter being a question of fact implicating the reliability of the testimony. Zimmer v. Peters, 176 Ariz. 426, 429 (App. 1993).

¶12 There is no debate Emmy's testimony was imprecise. She approximated the years the abuse took place and could not recall specific dates. She claimed Manseau attempted to abuse her in the car in 2022, even though she previously claimed it happened in the spring of 2020. Emmy's spotty memory, inability to discuss specific dates and times, and any other inconsistencies in testimony were for the jury to consider when determining her credibility and the weight of her testimony. See State v. Cox, 217 Ariz. 353, 357, ¶ 27 (2007); State v. Superior Court, 149 Ariz. 397, 400 (App. 1986).

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Bluebook (online)
State v. Manseau, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-manseau-arizctapp-2026.