Peo v. Estrada
23CA0669
| Colo. Ct. App. | Sep 19, 2024Background
- Luis Martin Estrada was convicted by a jury of first degree murder, four counts of attempted first degree murder, two counts of first degree assault, and three counts of menacing related to a shooting at a hotel party in October 2021.
- Estrada attended the party with his girlfriend and his friend, Ruben Mejia-Soto, who was identified as a potential alternate suspect.
- Witnesses saw Estrada with a gun, and after being asked to leave, a confrontation occurred, resulting in Estrada firing shots through a hotel room door, injuring four people and killing one.
- Gunshot residue was found on Estrada but not on Mejia-Soto; Mejia-Soto's DNA was on the gun and magazine, while Estrada's was not conclusively found there.
- Estrada sought to introduce evidence of a prior incident where Mejia-Soto had fired a gun at a party, to support his alternate suspect defense.
- The trial court excluded this prior act evidence, and Estrada appealed the evidentiary ruling, arguing it deprived him of a fair trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of alternate suspect's prior bad acts | Prior conduct not sufficiently distinctive; propensity only | Prior act showed scheme/plan, relevant to defense | Affirmed exclusion; insufficient similarity, propensity bar |
| Right to present alternate suspect defense | Defendant had other means to test state's evidence | Exclusion deprived fair trial/defense | No denial; allowed cross/defense theory at trial |
| Relevance and admissibility under Colorado law | Evidence lacked distinctive similarities per precedent | Should be allowed under alternate suspect case law | Evidence generic, lacking "signature" relevance |
| Harmlessness of any error | Overwhelming evidence of guilt; no substantial influence | Error was constitutional and unfair | Any error harmless; substantial unrelated evidence present |
Key Cases Cited
- People v. Elmarr, 2015 CO 53 (Colo. 2015) (sets standard for reviewing admissibility of alternate suspect evidence and relevance requirements)
- People v. Bueno, 626 P.2d 1167 (Colo. App. 1981) (discusses when prior bad acts by an alternate suspect are admissible—requires high degree of similarity)
- People v. Salazar, 2012 CO 20 (Colo. 2012) (discusses need for distinctiveness in prior acts to support inference of same actor)
- People v. Trusty, 53 P.3d 668 (Colo. App. 2001) (exclusion of alternate suspects’ prior criminal conduct where not distinctive)
- People v. Ornelas, 937 P.2d 867 (Colo. App. 1996) (admissibility of alternate suspect conduct requires more than generic similarities)