The People of the State of Colorado v. Elmo Jesse Johnson

Summary

The court held that a defendant may present truthful but potentially incomplete evidence without opening the door to previously suppressed evidence, even if the evidence could lead the jury to draw a misleading inference. The trial court therefore abused its discretion by conditioning admission of evidence supporting Johnson's alternate-suspect theory on admission of his suppressed gunshot-residue results, violating his right to present a complete defense. Because the ruling prevented presentation of evidence central to the defense and could have contributed to the conviction, the error was not harmless beyond a reasonable doubt.