International Rectifier Corp. v. Cohen

How later courts describe this case

• death penalty affirmed to nontrig-german where ‘heinous atrocious cruel’ and pecuniary gain aggravating circumstances applied vicariously
• where officers had reasonable suspicion that occupant of car was armed and dangerous, they were entitled to search accessible areas of the car
• homicides were committed to secure a vehicle in which assailants could continue their flight
• unnecessary murder of victims, including two-year-old child, in no position to thwart murderer's escape
• despite young age, minimal prior criminal activity of defendant, and convictions based on the felony murder rule, death penalty affirmed upon finding that the killings were done for pecuniary gain and in an especially cruel, heinous or depraved manner
• “conspiracy” instruction was proper although the defendant was not indicted for conspiracy
• though each of three victims' bodies were close enough to the other two that the shooting of any one of the three created a grave risk of danger to the other two, the indication that each victim was intentionally murdered foreclosed application of A.R.S. § 13-454(E)(3
• family members witnessed other family members' executions