v. Donald, 2020 CO 24

Defendant Laron Donald posted an appearance bond that expressly prohibited leaving Colorado without court and surety approval; the bond was one page and listed the out‑of‑state restriction under a bolded "Additional Conditions" heading.
Donald failed to appear for a court date; five weeks later he was stopped and arrested in Mississippi on the Colorado warrant and later extradited and charged with violating bail-bond conditions and failure to appear.
At trial the bondsperson testified about the jail’s routine (prisoners sign bond paperwork before release) and that she signed/posting the bond, but she did not identify Donald’s signature; the signed bond form was admitted into evidence.
Defense argued the prosecution failed to prove Donald actually signed or read the bond or had actual knowledge of the condition; defense counsel ultimately conceded the signature for strategic purposes at closing.
A unanimous Colorado Court of Appeals vacated the conviction for leaving the state, reasoning that the jury would have had to impermissibly ‘‘stack’’ inferences (per Tate) to infer Donald’s actual knowledge; the Colorado Supreme Court granted certiorari.
The Colorado Supreme Court reversed, holding that inference‑stacking is not per se dispositive in sufficiency review and that, viewing the evidence in the light most favorable to the prosecution, the evidence was sufficient to support a jury finding that Donald knowingly violated the bond condition.

Issue	People’s Argument	Donald’s Argument	Held
What role does the Tate prohibition on inference‑stacking play in sufficiency review?	Tate does not create an absolute bar; reasonable inferences (including chained inferences) are permissible under the modern substantial‑evidence test.	The Court of Appeals correctly applied Tate to block convictions based on stacked inferences.	Tate’s rule is not absolute; inference stacking is a factor/caution but not dispositive under the substantial evidence test.
Was there sufficient evidence to prove Donald knowingly violated the bond condition forbidding leaving the state?	Bondsperson’s testimony about routine signing, the admitted signed one‑page bond with the restriction prominently listed, and the concession about the signature permit a reasonable jury to infer Donald saw and knew the condition.	No witness identified Donald’s signature or testified he read or was informed of the condition; proving knowledge would require impermissible stacked inferences.	Evidence was sufficient: a reasonable jury could find Donald signed the single‑page form and saw the prominently listed condition, supporting a knowing violation.

Tate v. People, 247 P.2d 665 (Colo. 1952) (articulated the older prohibition on inference‑upon‑inference under a now‑outdated circumstantial‑evidence standard)
Holland v. United States, 348 U.S. 121 (U.S. 1954) (circumstantial evidence is not different from testimonial evidence and juries may draw on common experience; prosecution need not exclude every reasonable hypothesis)
People v. Bennett, 515 P.2d 466 (Colo. 1973) (adopted the substantial‑evidence test for sufficiency review, treating direct and circumstantial evidence equally)
Clark v. People, 232 P.3d 1287 (Colo. 2010) (describes de novo review and sufficiency standard)
People v. Perez, 367 P.3d 695 (Colo. 2016) (reasonable inferences must have a logical and convincing connection to the facts)
United States v. Summers, 414 F.3d 1287 (10th Cir. 2005) (inference‑stacking is a cautionary signpost—chains of inferences may become too attenuated but are not automatically invalid)