The People of the State of Colorado v. Maria Laida Day

Summary

The court affirmed the court of appeals’ reversal of Maria Day’s convictions and remanded for a new trial because the trial court improperly excluded her expert mental-condition evidence after treating her noncooperation during an examination conducted while she was incompetent as grounds for exclusion. The court held that a defendant must be competent before undergoing the statutory mental-condition examination and that the trial court should have required the examination while Day was competent. It also held that the trial court improperly excluded all of the proffered testimony without separating evidence probative of insanity from evidence admissible for another defense, while leaving the separate evidentiary balancing under CRE 403 for the trial court on remand.