Supreme Court of Colorado
Reginald Keith Clark v. the People of the State of Colorado.
July 1, 20242024 CO 55
Summary
The court held that the trial court's erroneous denial of Clark's for-cause challenge to a juror who expressed racial bias was subject to harmless-error review, not structural-error review, because the error was made in good faith and the juror was removed by a peremptory challenge before serving. The court also held that the juror affidavit describing a prior judge's statement about deliberating until unanimity did not present extraneous prejudicial information under CRE 606(b). The court therefore affirmed Clark's conviction.