b. Absence of past Violent Acts.

• Jurisdiction: Arizona

i. Specific Circumstances.

(1) Given Weight as Mitigation.

• Where the prior record did not reveal a tendency toward violent crime, only juvenile property crimes, and the presentence report described the defendant as nonaggressive and passive. Graham, 135 Ariz. at 213.

• Where the defendant had exhibited very little violent behavior or spousal abuse. Stanley, 167 Ariz. at 529.

(2) Not Given Weight as Mitigation.

• Where the defendant presented letters attesting to his non-violent character, but the evidence reflected planning; the Court

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