The People of the State of Colorado, Petitioner v. Michael Joseph McKimmy, Respondent

Summary

The court held that, when a prisoner invokes the UMDDA through substantial rather than strict compliance, "actual notice" requires the prosecution's actual knowledge of the request, not merely receipt of the document. Because the record did not establish when prosecutors learned of the requests, the court reversed the court of appeals and remanded for factual findings concerning the triggering dates and any resulting statutory violations.