People v. Lancaster
373 P.3d 655
Colo. Ct. App.2015Background
- Lancaster convicted by jury of kidnapping, two counts sexual assault, menacing, and third-degree assault; DNA profile linked to the offender; trial court admitted DNA evidence despite Katie's Law issues.
- Police collected buccal swabs after Lancaster’s misdemeanor police contacts; first two swabs taken before felony charges; Crim. P. 41.1 order led to third DNA sample.
- Defendant sought to suppress DNA evidence, arguing violations of Katie's Law and constitutional rights; trial court denied suppression finding lack of willful violation.
- Lancaster sought to admit evidence of victim’s history of false sexual assault reports under rape shield statute; trial court denied an evidentiary hearing.
- Trial court later sentenced Lancaster to indeterminate life terms for sexual assaults; the court’s understanding of sentencing ranges was unclear.
- Court affirms judgment, vacates sexual assault sentences, and remands for resentencing consistent with statutory ranges and Blakely requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| DNA evidence suppression denial? | Lancaster asserts suppression due to Katie’s Law violations. | Lancaster contends unconstitutional collection tainted evidence. | No reversible error; searches did not violate Fourth Amendment protections. |
| Rape shield evidence admissibility? | Lancaster seeks admission of victim’s false-report history. | Lancaster’s offer of proof insufficient to show multiple false reports. | No evidentiary hearing required; offer of proof insufficient. |
| Right to present complete defense? | Admission of rape shield evidence would aid defense. | No viable defense testing weakened by ruling. | No plain error; defense not meaningfully impeded. |
| Sentencing range misapprehension remand? | Court misapprehended presumptive range; can remain within range. | Aggravating factors justify deviation if properly found. | Remand for resentencing due to possible misapprehension of range. |
Key Cases Cited
- King v. Maryland, 133 S. Ct. 1958 (2013) (DNA sampling as reasonable booking procedure; reduced privacy interests while detained)
- People v. Casillas, 2015 COA 15 (Colo. App. 2015) (rape shield exceptions for false reporting require sufficient offer of proof)
- People v. Weiss, 133 P.3d 1180 (Colo. 2006) (rape shield statute exceptions; admissibility framework)
- People v. Villa, 240 P.3d 343 (Colo. App. 2009) (indeterminate sentencing framework under Sex Offender Lifetime Supervision Act)
- Linares-Guzman v. People, 195 P.3d 1130 (Colo. App. 2008) (remand when trial court misapprehends sentencing range)
- People v. Hunsaker, 2015 CO 46 (Colo. 2015) (sex offense sentencing under the act; factors for variation)
- People v. Brunsting, 307 P.3d 1073 (Colo. 2013) (standard for reviewing suppression rulings; de novo on legal conclusion)
- Casillas, 140 P.3d 172 (Colo. App. 2006) (privacy interests of probationers and arrestees; special needs)