State v. Zamora

Court of Appeals of Arizona·Decided August 13, 2026·No. 1 CA-CR 25-0138·Unpublished·D. Steven Williams

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UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.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

BRANDON KENNETH ZAMORA, Appellant.

No. 1 CA-CR 25-0138

FILED 08-13-2026

Appeal from the Superior Court in Maricopa County No. CR2024-006111-001

The Honorable Monica Edelstein, Judge

AFFIRMED

COUNSEL

Feldman Royle Ahl, PLLC, Phoenix By David E. Ahl Counsel for Appellant

Arizona Attorney General’s Office, Phoenix By Joseph A. Newburg, II Counsel for Appellee

Decision of the Court

MEMORANDUM DECISION

Presiding Judge D. Steven Williams delivered the Court’s decision, in which Judge Anni Hill Foster, and Vice Chief Judge David D. Weinzweig joined.

W I L L I A M S, Judge:

¶1 Brandon Kenneth Zamora appeals his convictions and sentences. For the following reasons, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

¶2 The State charged Zamora with eight counts of sexual conduct with a minor (Counts 1–7 and 11), two counts of furnishing obscene or harmful items to minors (Counts 8 and 12), one count of molestation of a child (Count 9), and one count of attempt to commit sexual conduct with a minor (Count 10), alleging he sexually abused his niece (“Simone”) and nephew (“Conrad”) (collectively, “the victims”) on multiple occasions.1 The State also alleged numerous aggravating circumstances.

¶3 Nearly three months before trial, the State moved to dismiss Count 2, renumber the indictment, and amend it. Specifically, and as relevant to this appeal, the State moved to amend Count 7 by changing the “to wit” language describing the location of the offense. 2 In making this request, the prosecutor avowed that he had provided defense counsel with the proposed amendment and counsel had “indicated” he had “no objection to the motion.”

¶4 Because the superior court took no action on the motion, the State moved to amend the indictment a second time approximately three weeks before the trial start date. As part of that motion, the prosecutor again represented that he had contacted defense counsel about the proposed

1 We use pseudonyms to protect the identity of victims and witnesses. See Ariz. R. Sup. Ct. 111(i).

2 For clarity, we refer to all counts as numbered in the original indictment.

Decision of the Court

amendment and defense counsel had “indicated” he had “no objection to the motion.”

¶5 At a trial procedure conference held the next day, defense counsel waived Zamora’s presence, and the superior court addressed the State’s outstanding motions. After confirming that counsel did not object, the court dismissed Count 2 and granted the unopposed motion to amend the indictment.

¶6 The matter then proceeded to trial. After presenting the State’s case-in-chief, the prosecutor moved for a directed verdict in Zamora’s favor on Counts 6 and 11, which the superior court granted. A jury then convicted Zamora of the remaining charges, finding that Simone was under 12 years of age and Conrad was under 15 years of age when the offenses occurred.

¶7 After denying Zamora’s motion for new trial, the superior court sentenced him to life with the possibility of release after 35 years on Count 3 and consecutive and concurrent presumptive terms of imprisonment on the other counts, totaling an additional 107 years. Zamora timely appealed. We have jurisdiction under Article 6, Section 9, of the Arizona Constitution and A.R.S. §§ 12-120.21(A)(1), 13-4031, and -4033(A)(1).

DISCUSSION

I. Amendment of the Indictment

¶8 Zamora argues that the superior court improperly granted the State’s motion to amend Count 7. He contends the amendment violated Arizona Rule of Criminal Procedure (“Rule”) 13.5(b) and deprived him of “his constitutional right to a probable cause determination and to notice of the charges against him.”

¶9 Because Zamora failed to challenge the amendment in the superior court, he has forfeited review for all but fundamental, prejudicial error. See State v. Escalante, 245 Ariz. 135, 140, ¶ 12 (2018); see also State v. Freeney, 223 Ariz. 110, 114, ¶ 26 (2009) (holding “a violation of Rule 13.5(b) is neither prejudicial per se nor structural error”). To establish fundamental error, a defendant must show error that: (1) went to the foundation of his case, (2) denied him a right essential to his defense, or (3) was so egregious as to deny him the possibility of a fair trial. Escalante, 245 Ariz. at 142, ¶ 21. Under the first two prongs, a defendant must also show prejudice. Id. If a

Decision of the Court

defendant “establishes the third prong, he has shown both fundamental error and prejudice, and a new trial must be granted.” Id.

¶10 Both the United States Constitution and the Arizona Constitution guarantee criminal defendants the right to know the nature and cause of the accusations against them. U.S. Const. amend. VI (“In all criminal prosecutions, the accused shall enjoy the right . . . to be informed of the nature and cause of the accusation. . . .”); see also Ariz. Const. art. 2, § 24 (“In criminal prosecutions, the accused shall have the right . . . to demand the nature and cause of the accusation against him. . . .”). Consistent with this constitutional mandate, an indictment provides “a plain, concise statement of the facts sufficiently definite to inform the defendant of a charged offense.” Ariz. R. Crim. P. 13.1(a).

¶11 Apart from satisfying the notice requirement, an indictment: (1) “ensure[s] that a neutral intermediary—a grand jury comprised of ordinary citizens—finds that probable cause exists before the State can bring charges,” McKaney v. Foreman ex rel. Cnty. of Maricopa, 209 Ariz. 268, 274–75, ¶ 31 (2004) (Hurwitz, J., dissenting in part and concurring in part) (citing Ariz. Const. art. 2, § 30 (“No person shall be prosecuted criminally . . . otherwise than by information or indictment. . . .”)); and (2) establishes trial boundaries—limiting the scope “to the specific charge or charges” alleged, Ariz. R. Crim P. 13.5(b). “Unless the defendant consents, a charge may be amended only to correct mistakes of fact or remedy formal or technical defects.” Id. (emphasis added). Under this “prophylactic rule of criminal procedure,” Freeney, 223 Ariz. at 114, ¶ 25, an amendment that changes the nature of an offense—by either changing the factual allegations or the legal description of the elements—is impermissible absent the defendant’s consent, State v. Montes Flores, 245 Ariz. 303, 307, ¶ 16 (App. 2018).

¶12 Here, the amendment to Count 7 did not change the legal description of the elements of the offense. Both in the original and the amended indictment, the State alleged that “Zamora, on or between August 20, 2009, and August 24, 2011, intentionally or knowingly did engage in sexual intercourse or oral sexual contact with [Simone], who was a minor under the age of fifteen years” in violation of A.R.S. § 13-1405.

¶13 But the State charged Zamora with numerous counts of sexual conduct with a minor and differentiated between these counts by including “to wit” language describing the nature and location of each offense. Specific to Count 7, the State moved to change the original “to wit” language from “oral/penile – another time in the garage when victim was with a cousin” to “time when victim was in the bathtub.”

Decision of the Court

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