Colorado v. Jones

J.R. was sexually assaulted by a man who offered her a ride as she was walking home at 2:00 A.M. one winter morning in 2005. J.R. was taken to the hospital for examination; she complained of neck and jaw pain stemming from when her assailant held her mouth shut. A presence of semen later implicated Respondent Michael Jones as J.R.'s assailant. The State charged respondent with numerous offenses. Prior to trial, he moved the trial court to bar the State from introducing evidence that he allegedly sexually assaulted two other women in two other states. The trial court denied the motion, finding the evidence of the two other alleged assaults under the four-part "Spoto" admissibility test allowed the evidence's admissibility to show respondent's "common plan, scheme, or design" and to rebut respondent's defense of consent (Colorado v. Spoto, 795 P.2d 1314 (1990)). A jury ultimately convicted respondent, but the appellate court reversed, finding that evidence of the two out-of-state assaults were not sufficiently similar to the Colorado assault. The Supreme Court reversed the appellate court. The Supreme Court held that trial courts have no obligation to determine that evidence of other acts offered under the Colorado Rules of Evidence satisfy the doctrine of chances, and to also satisfy the second and third prongs of the Spoto admissibility test. Though the doctrine of chances provides one theory pursuant to which other-act evidence may satisfy components of the Spoto analysis, trial courts have discretion to assess the relevance of other-act evidence under Spoto apart from the doctrine. The court of appeals therefore erred when it effectively held that the trial court abused its discretion by admitting the other-act evidence without conducting a doctrine of chances analysis.View "Colorado v. Jones" on Justia Law