Supreme Court of Colorado
20SC399 - Rojas v. People
February 22, 2022504 P.3d 296
Summary
The court abolished Colorado's res gestae doctrine in criminal cases, holding that uncharged misconduct must be evaluated under the modern Rules of Evidence rather than admitted through res gestae as a standalone basis. It held that the later food-stamp application was extrinsic character evidence subject to CRE 404(b) and the required analytical and procedural safeguards, and that admitting it without those safeguards was not harmless. The court reversed the court of appeals and remanded for a new trial.