Julio Venalonzo, A/k/a Melvin Manzanares(z) v. the People of the State of Colorado

Summary

The concurrence agrees with reversing the court of appeals’ judgment and the defendant’s sexual-assault-related convictions, but rejects the majority’s methodology and its treatment of lay opinion, expert opinion, and credibility evidence. It reasons that admissibility must be determined by the actual language and integrated structure of the evidentiary rules, rather than by categorical rules focused on whether evidence bolsters a witness. The concurrence would exclude the forensic interviewer’s testimony because it relied on training and education without expert qualification, and the mother’s testimony because it lacked an adequate foundation.