The People of the State of Colorado v. Erin D. Janis

Summary

The court held that an in-custody defendant need not receive a formal, on-the-record advisement before waiving the constitutional right to be present during trial. The validity of the waiver depends on the totality of the circumstances, including whether it was knowing, intelligent, and voluntary, and the record established those elements here. The court therefore reversed the court of appeals and remanded for consideration of any unresolved issues.