Nicholas Javier Zapata, Petitioner v. the People of the State of Colorado, Respondent.

Summary

The court affirmed Zapata's convictions, holding that Murillo's competency reports were protected by the physician-patient or psychologist-client privilege, that any statutory waiver was limited to Murillo's own criminal case, and that Zapata had not shown a sufficient basis for disclosure or in camera review. The court also held that any error in admitting evidence of Zapata's prior threatening and abusive behavior toward S.M. was harmless because the properly admitted evidence of guilt was strong. Justice Hart, specially concurring, agreed with the result but criticized the res gestae doctrine, while Justice Samour, dissenting, would have required disclosure of the competency report and a prejudice inquiry.