Jason P. Brown v. the People of the State of Colorado

Summary

The court affirmed Brown's convictions for leaving the scene of an accident resulting in death and serious bodily injury without requiring proof of a culpable mental state. It held that the governing precedent remained controlling, that subsequent statutory amendments and later authority did not require implying a mens rea, and that the habitual offender statute was not facially unconstitutional. Any error in allowing the judge rather than the jury to determine whether prior convictions arose from separate criminal episodes was harmless beyond a reasonable doubt.