The People of the State of Colorado v. Matthew Francisco Alfaro

Summary

The court held that the court of appeals improperly reversed Alfaro's convictions based on presumed prejudice from the trial court's good-faith denial of an additional peremptory challenge. Because the alleged error was trial error, the court of appeals was required to evaluate whether it affected the verdict under an outcome-determinative harmless- or plain-error standard. The judgment was reversed and remanded for that analysis. Justice Hood, joined by Justice Hobbs, dissented because he would retain the automatic-reversal rule for improper impairment of peremptory challenges.