Colorado v. Laeke

The Supreme Court reviewed the court of appeals' opinion in "People v. Laeke" (08CA79 (Colo. App. Feb. 4, 2010)). The court held that when the prosecution has conceded that defendant was insane at the time of the commission of the crime, he has a statutory right under Colorado's insanity statutes to a jury trial on both the merits and the affirmative defense of insanity. The court of appeals further held that a defendant's constitutional rights are violated when a judgment of not guilty by reason of insanity (NGRI) is entered without a trial. After review of the applicable legal authority and court precedent, the Supreme Court held that a defendant does not have a statutory right to a jury trial on the merits and his affirmative defense of insanity when he enters a NGRI plea and the prosecution concedes defendant was insane. "The legislature articulated its intent when it amended the insanity statutes. The explicit legislative wording did not include an intent to create a substantive statutory right to a jury trial on the merits and the affirmative defense of insanity after it has been established that the defendant was insane at the time of the commission of the crime." The Court held that the Constitution is not violated when NGRI is entered without a trial on the merits and an affirmative defense of insanity. The Court reversed the court of appeals and remanded this case to the trial court for further proceedings. View "Colorado v. Laeke" on Justia Law