Lori Alexis Martin v. the People of the State of Colorado

Summary

The court held that a trial court need not advise a deadlocked jury that failure to reach unanimity will result in a mistrial when giving a modified-Allen instruction. It also held that the supplemental instruction given after the jury's nonunanimous poll, read together with the modified-Allen instruction, was not coercive, and that the record did not show that scheduling information imposed a deliberation deadline. Justice Coats, joined by the Chief Justice and Justice Eid, concurred in part and in the judgment but rejected the majority's view that trial courts have discretion to give a mistrial advisement in rare circumstances.