People v. William Robert Eason, 21CA0962

Background

Defendant William Eason was charged with assault and two counts of menacing after an altercation with two teenage siblings; trial was set for March 1, 2021.
Colorado Supreme Court amended Crim. P. 24(c)(4) during COVID-19 to allow a court to declare a mistrial before trial if a fair jury pool cannot be safely assembled; the district court sua sponte declared a mistrial under that rule on March 1, 2021 and reset the trial.
Eason moved to dismiss (speedy trial and separation-of-powers challenges), objected to the mistrial, and later sought dismissal for discovery violations after the sheriff’s office inadvertently deleted a deputy’s bodycam recording and the prosecution belatedly produced two victims’ written statements.
The district court denied dismissal for speedy trial and for destruction of the bodycam video (finding no bad faith and no apparent exculpatory value), dismissed one menacing count as a sanction for the late statement, and proceeded to trial on remaining charges.
A jury convicted Eason of menacing (acquitted on assault); on appeal he argued Rule 24(c)(4) is unconstitutional, the mistrial lacked sufficient findings, and the discovery failures required dismissal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of Crim. P. 24(c)(4) under separation of powers	Rule is a valid court procedural rule adopted under the supreme court’s rulemaking authority	Rule usurps legislative/executive powers over public health and emergency measures	Court: Rule is procedural, within judicial rulemaking power; no conflict with statute or executive orders, so no separation-of-powers violation
Validity of mistrial declaration and adequacy of findings	Mistrial under Rule 24(c)(4) was justified by COVID-related capacity/health limits; court made specific findings	Mistrial unjustified; court could have managed docket differently and findings didn’t address his particular case	Court: District court made specific findings tied to health orders and courthouse limits; no abuse of discretion in declaring mistrial
Destruction of deputy’s bodycam recording — due process remedy	State: deletion was inadvertent, other materials provided; no apparent exculpatory value and no bad faith	Eason: deletion deprived him of potentially exculpatory impeachment evidence; dismissal required	Court: Deletion inadvertent; defendant failed to show apparent exculpatory value or bad faith; dismissal not warranted
Late disclosure of victims’ written statements — remedy	State: belated disclosure inadvertent and statements were largely inculpatory; lesser sanctions suffice	Eason: late disclosure prejudiced defense; dismissal required	Court: Trial court imposed targeted remedy (dismissed one count) and offered jury instruction; record insufficient to show abuse of discretion in refusing full dismissal

Key Cases Cited

Wiedemer v. People, 852 P.2d 424 (Colo. 1993) (distinguishing procedural rules from substantive law for separation-of-powers analysis)
Borer v. Lewis, 91 P.3d 375 (Colo. 2004) (overlap of legislative policy and judicial rulemaking permitted absent substantial conflict)
Braunthal v. People, 31 P.3d 167 (Colo. 2001) (test for due process when state fails to preserve potentially exculpatory evidence)
Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988) (no due process violation absent bad faith in destruction of potentially useful evidence)
California v. Trombetta, 467 U.S. 479 (U.S. 1984) (bad faith includes conscious effort to suppress exculpatory evidence)
Holloway v. People, 649 P.2d 318 (Colo. 1982) (destruction of recordings can violate due process where tapes had clear exculpatory value)
People v. Segovia, 196 P.3d 1126 (Colo. App. 2008) (mistrial appropriate where manifest necessity or public justice requires)
People v. Daley, 97 P.3d 295 (Colo. App. 2004) (speculative possibility that destroyed evidence might be exculpatory insufficient for dismissal)