Brooke E. Rojas v. the People of the State of Colorado

Summary

The court abolished Colorado's res gestae doctrine in criminal cases because it was vague, duplicative of the modern Rules of Evidence, and enabled uncharged-misconduct evidence to evade the safeguards governing character evidence. It held that courts must first determine whether uncharged conduct is intrinsic or extrinsic to the charged offense, and whether it implicates character; the August application was extrinsic character evidence subject to Rule 404(b), and admitting it without the required analysis or limiting instruction was not harmless. The court reversed the court of appeals and remanded for a new trial.