People v. Laeke
2012 CO 13
Colo.2012Background
- Laeke charged with one count of criminal attempt to commit unlawful sexual contact and one count of indecent exposure at Denver Health Medical Center (2004).
- Preliminary hearing found probable cause and charges bound over for district court proceedings.
- At arraignment, Laeke’s NGRI plea was entered over objection; prosecution stipulated to insanity on the date of the offense.
- District court accepted the NGRI plea and committed Laeke to the Department of Human Services.
- Court of Appeals held a statutory and constitutional right to a jury trial on the merits and insanity defenses existed; reversed and remanded.
- Colorado's insanity statutes were amended in 1996 to a unitary trial system for offenses after July 1, 1995, replacing the prior bifurcated system for sanity and guilt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there a statutory right to a jury trial when NGRI is entered and the People stipulate insanity? | Laeke; statutory right exists under 16-8-105.5. | Laeke; changes in 1996 create a substantive right to jury trial. | No statutory right to a jury trial in this scenario. |
| Does the Sixth Amendment require a jury trial when NGRI is found without trial on guilt or insanity? | Laeke; constitutional rights violated by NGRI judgment without trial. | No constitutional violation; NGRI is an acquittal. | No Sixth Amendment violation; NGRI judgment stands as acquittal. |
| Did the 1996 unitary trial reforms reflect legislative intent to create a jury-trial right in these circumstances? | Laeke; unitary system implies jury right on merits. | Changes were procedural, not to create a substantive right. | Unitary system does not create a new statutory right to jury trial when insanity is conceded. |
Key Cases Cited
- People ex rel. Juhan v. Dist. Court, 165 Colo. 253 (Colo. 1968) (mental capacity essential to guilt; mens rea exists)
- Hendricks v. People, 10 P.3d 1231 (Colo. 2000) (balance test for NGRI plea necessity)
- People v. Hill, 934 P.2d 821 (Colo. 1997) (conditions for sanity determinations and trial requirements)
- Jacobs v. Carmel, 869 P.2d 207 (Colo. 1994) (insanity as complete defense; not a conviction)
- Parks v. Dist. Court, 503 P.2d 1029 (Colo. 1972) (insanity as complete defense; bifurcated approach)
- Les v. Meredith, 561 P.2d 1256 (Colo. 1977) (insanity statutes constitutionality where NGRI entered over objection)
- Martinez v. Continental Enters., 730 P.2d 308 (Colo. 1986) (statutory interpretation; use of titles in construction)
- Vigil v. Franklin, 103 P.3d 322 (Colo. 2004) (statutory intent and interpretation rules)