Justia Colorado Supreme Court Opinion Summaries

Petitioner Douglas Wilson was charged with first degree murder. He was appointed a public defender, but citing a conflict of interest, Wilson insisted upon new representation. The trial court determined that Wilson either had to keep the same lawyer or represent himself. Wilson opted to represent himself with assistance from advisory counsel. At a subsequent hearing, a question over Wilson's competency to stand trial became an issue. After being deemed competent as long as he was on his medications, Wilson went through two more attorneys until six days prior to trial when Wilson alleged he was no longer competent to stand trial. The trial court disagreed with Wilson's allegations, and he continued to represent himself with limited help. A jury ultimately found him guilty. Wilson appealed his conviction through counsel, and the court of appeals affirmed the conviction. Petitioner William Beaty was charged with assault, criminal mischief, tampering with a victim or witness, and intimidating a victim or witness. A public defender was appointed to represent Beaty, but that counsel was dismissed and Beaty elected to represent himself. After his Arguello advisement, Beaty chose not to represent himself, and accepted the help of a public defender. Beaty stated that his original decision to proceed pro se was due in part to his failing to take his medications to control bipolar disorder and schizophrenia. On the first day of trial, Beaty expressed a renewed desire to represent himself due to a conflict with his public defender. Beaty represented himself throughout the trial, and a jury found him guilty of all charges. The Colorado Supreme Court granted certiorari in Williams' and Beaty's cases to determine whether to adopt a new competency standard for mentally ill defendants in light of "Indiana v. Edwards," (554 U.S. 164 (2008)). The Court declined to create a new standard, and affirmed the court of appeals' decisions to retain the existing analytical framework. View "Wilson v. Colorado" on Justia Law

The State charged defendant Rashaim Davis with possession and distribution of a schedule II controlled substance after Davis allegedly sold 0.372 grams of crack cocaine to an undercover detective. The State appointed a series of attorneys to represent Davis, but he refused to cooperate with any of his lawyers. He also threatened to harm at least one lawyer and wanted an investigator from the public defender's office that he might harm her if she made him uncomfortable. Several of Davis' lawyers questioned whether he was competent to proceed because at times he "exhibited a flat affect, bordering on catatonic." Prior to trial, Davis told the trial court he wanted to represent himself. Davis was taking several medications for his "bipolarism," and that he had a mistrust of lawyers resulting from paranoia that the medications did not completely control. The trial court was not convinced that Davis could proceed pro se; the case was tried with court-appointed counsel. A jury found Davis guilty of all counts. Davis appealed the trial court's denial of his requests to represent himself and his subsequent convictions to the court of appeals. The court of appeals reversed the trial court's order denying Davis' request to represent himself, citing the U.S. Supreme Court's decision in "Indiana v. Edwards," (554 U.S. 164 (2008)). The Colorado Supreme Court reversed, declining to adopt a new competency standard for mentally ill defendants pursuant to "Edwards." Furthermore, the Court reversed the appellate court's failing to order the trial court to merge Davis' possession and distribution convictions during sentencing. View "Colorado v. Davis" on Justia Law

The Colorado Supreme Court granted certiorari in this case to resolve a split of authority between divisions of the court of appeals on whether double jeopardy barred a new habitual criminal sentencing hearing when the trial court erroneously dismissed the habitual counts before the State presented any evidence as to those counts. In 2002, Reginald Porter robbed and attempted to sexually assault a casino worker. He tried to evade capture after a police chase. Based on these events, the State charged Porter with two counts of first degree burglary and one count each of aggravated auto theft, attempted sexual assault, aggravated robbery, vehicular eluding and third degree assault. The prosecution added habitual counts later. A jury found Porter guilty of all charges. The trial court adjudicated Porter as a habitual offender. Porter appealed, and the court of appeals reversed and remanded for a new trial. At the second trial, Porter waived his right to trial by jury, and the court found him guilty of most of the substantive charges. Before the habitual phase, Porter moved to dismiss the habitual counts. The trial court was persuaded by his arguments, and the counts were dismissed. The court of appeals concluded, in pertinent part, that double jeopardy precluded a new habitual criminal sentencing hearing. The court relied on the Supreme Court's opinion in "Colorado v. Quintana," (634 P.2d 413 (Colo. 1981)) to conclude that jeopardy attached during the substantive phase of trial, and carried through to the habitual phase. Since Quintana, the U.S. Supreme Court has held that federal constitutional double jeopardy protections do not apply to habitual criminal proceedings. After review, the Colorado Supreme Court held that Colorado double jeopardy law did not apply to noncapital sentencing proceedings. Accordingly, double jeopardy did not bar trial of defendant's habitual counts in this case. View "Colorado v. Porter" on Justia Law

In 2007, a man made sexual advances toward two teenaged girls in a bathroom of a horse-facing facility in which petitioner Miguel Pena-Rodriguez worked. The girls identified petitioner as the assailant at a one-on-one show-up. The State charged petitioner with one count of sexual assault on a child, one count of unlawful sexual contact, and two counts of harassment. At the start of a three-day trial, the venire received a written questionnaire. None of the jurors that were impaneled answered any question pertaining to any biases, or if they were unable to be fair on their respective questionnaires. After trial, the jury ultimately found petitioner guilty on all but the attempted sexual assault charge. Two weeks later, petitioner moved the trial court for juror contact information, alleging that some members of the jury used ethnic slurs in the course of deliberations. Defense counsel obtained affidavits from some jurors suggesting that one juror exhibited racial bias against petitioner during deliberations. The issue this case presented for the Supreme Court's review centered on the secrecy of those deliberations and petitioner's constitutional right to an impartial jury. Specifically, the issue was whether CRE 606(b) applied to such affidavits, and if so, whether the Sixth Amendment nevertheless required their admission. The Supreme Court concluded that the affidavits fell within the broad sweep of CRE 606(b), and that they did not satisfy the rule's "extraneous prejudicial information" exception. The Court held that the trial court's application of CRE 606(b) did not violate petitioner's Sixth Amendment right to an impartial jury. View "Pena-Rodriguez v. Colorado" on Justia Law

While incarcerated, defendant Josph Diaz punched a prison guard. Less than three months later, Diaz threw a cup that hit another guard in the mouth. The district attorney charged him in two cases with second degree assault of a detention center employee. Diaz finished finishing his original sentence before he went to trial in either assault case. Trial for the second assault took place before trial for the first. A jury found Diaz guilty, and the court sentenced him to ten years for the second (cup-throwing) assault. Shortly thereafter, another jury found Diaz guilty of the first assault, and he was sentenced to ten years consecutive to the ten he was sentenced for the second assault. The Court of Appeals held that the trial court erred by ruling that 18-3-203(1)(f), C.R.S. (2014) required that the sentences be served concurrently. The Supreme Court reversed: 18-3-203(1)(f) required a consecutive sentence if, at the time of sentencing, a defendant was serving any other sentence. View "Colorado v. Diaz" on Justia Law

The State filed an interlocutory appeal of a trial court's order suppressing the results of a blood draw taken from defendant-appellee Travis Ackerman. At the hearing, the trial court found that a warrant was required before the police could order a blood draw and that the police lacked exigent circumstances that would justify the involuntary, warrantless blood draw under the Fourth Amendment. The State appealed on the issue of whether the facts of the case constituted exigent circumstances. The Supreme Court held that under the specific facts of this case, exigent circumstances existed: police were still investigating the scene of the crime and were not finished preparing the affidavit for a warrant they learned that the hospital personnel were taking the unconscious and injured defendant for the medical procedures that could alter his blood-alcohol content. Under the totality of the circumstances, these exigent circumstances made it impractical for the police to obtain a search warrant and justified the blood draw. Accordingly, the Court reversed the trial court's suppression order and remanded the case for further proceedings. View "Colorado v. Ackerman" on Justia Law

Defendant Zachariah Jones petitioned the Supreme Court to appeal a district court's decision to revoke his bail bond in its entirety, and ordered that he be held without bond pending resolution of charges in a different district. Defendant was arrested, charged and released on bond in connection with several felony drug offenses in Denver County. Several months later, the Denver District Attorney moved to revoke bond, alleging that while Jones was released on bond, a court in Adams County issued a warrant for his arrest, based on an assault charge. The Denver district court concluded that because another court had found probable cause to believe defendant committed another felony, it had the statutory authority to revoke bond. The Court of Appeals found it lacked jurisdiction to review the Denver district court's judgment according to an expedited procedure listed in 16-4-205 (3), C.R.S. (2014). The Supreme Court reversed and remanded after review, concluding the appellate court erred in concluding that it lacked jurisdiction to entertain the appeal. "Because section 105(3) merely empowered the district court to have Jones brought before it for purposes of modifying the conditions of his pretrial release, the district court erred in revoking his existing bond and denying him a right to pretrial release altogether." The matter was remanded to the district court with directions to reinstate defendant's bail bond. View "In re Colorado v. Jones" on Justia Law

In an interlocutory appeal, the State challenged the trial court's order suppressing statements made by defendant Douglas Thames during a custodial interrogation. Investigators gave defendant an oral Miranda advisement, defendant confirmed that he understood them, and he then signed a written waiver for before making the statements the prosecution wished to use in its case-in-chief. The trial court, relying on a defense expert witness who testified that defendant had difficulty understanding spoken paragraphs concerning abstract ideas, concluded that defendant did not knowingly or intelligently waive his Miranda rights. Reviewing the totality of the circumstances, the Supreme Court concluded that defendant indeed knowingly and intelligently waived his rights. Therefore, the Court reversed the trial court's order. View "Colorado v. Thames" on Justia Law

Petitioner Joe Anthony Martinez was convicted by jury for first-degree murder after deliberation under a complicity theory. When the court instructed the jury on "after deliberation," it used language that the Supreme Court had previously held as constitutionally deficient. At trial, defense counsel objected to the language on grounds that it was cumulative and unnecessary, but erroneously acknowledged that it correctly stated the law. The trial court overruled the objection and the jury found defendant guilty as charged. On appeal, petitioner raised for the first time the argument that the Supreme Court previously disapproved the definition of "after deliberation" used in the jury instructions, and that the erroneous instruction was so prejudicial as to require reversal as plain error. He also renewed claims that the evidence presented against him was insufficient to sustain his conviction. The court of appeals reviewed the instruction for plain error and ultimately upheld petitioner's conviction. Finding no reversible error in the court of appeal's judgment, the Supreme Court also affirmed. View "Martinez v. Colorado" on Justia Law

The Department of Corrections directly appealed to the Supreme Court the grant of habeas relief to petitioner-appellee Randal Ankeney. Complying with a mandate from the court of appeals (in an earlier appeal), the district court interpreted various statutory provisions regarding good time and earned time credit to require Ankeney's release from prison almost three years before the date calculated by the Department. Because the lower courts erred in their conclusions that for inmates convicted after July 1, 1993, good time credits awarded pursuant to C.R.S. 17-22.5-301 (2014), were to be applied against an inmate's mandatory release date rather than to determine his parole eligibility. The Supreme Court concluded that had the credits been properly applied, Ankeney had not completed service of his required parole term. Therefore, the Supreme Court reversed the district court's order. View "Ankeney v. Raemisch" on Justia Law