Juvenal Onel Garcia, Petitioner v. the People of the State of Colorado, Respondent.

Summary

The court held that use of a model jury instruction does not automatically preclude plain-error relief, but affirmed because any omission concerning the mens rea for causing submission could not reasonably have contributed to Garcia's conviction or undermined the trial's fundamental fairness. The court also held that the physical-force sentence enhancer for sexual assault does not require proof that the defendant acted knowingly. The court declined to decide whether obviousness is assessed at trial or on direct appeal because the instructional error was nonprejudicial.