inconsistent defense (Colorado) · Go Syfert
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inconsistent defense in Colorado

8 Colorado opinions name it 2 courts 1984–2024 1 in the last five years

The cases below were cited by Colorado courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (3)

CaseFollowedCited
Seegars v. Stategreen
oklacrimapp · 1982 · cited in 1 Colorado opinions naming this issue, 2010–2010
2 sentences

2010The Spuchler court held that the defendant was automatically barred from raising an inconsistent defense, reasoning that "[when a defendant, who has a right of election as to several defenses, takes the stand as a witness and makes such admissions as to render every theory of defense unavailable save one, he will be deemed to have elected that one." Id. (quoting Seegars v. State, 655 P.2d 563, 565 (Okla.Crim.App.1982); Jones v. State, 555 P.2d 1061, 1070 (Okla.Crim.App.1976)).

2010The Spuehler court held that the defendant was automatically barred from raising an inconsistent defense, reasoning that "[w]hen a defendant, who has a right of election as to several defenses, takes the stand as a witness and makes such admissions as to render every theory of defense unavailable save one, he will be deemed to have elected that one." Id. (quoting Seegars v. State, 655 P.2d 563, 565 (Okla.Crim.App.1982); Jones v. State, 555 P.2d 1061, 1070 (Okla.Crim.App.1976)).

11
Jones v. Stategreen
oklacrimapp · 1976 · cited in 1 Colorado opinions naming this issue, 2010–2010
2 sentences

2010The Spuchler court held that the defendant was automatically barred from raising an inconsistent defense, reasoning that "[when a defendant, who has a right of election as to several defenses, takes the stand as a witness and makes such admissions as to render every theory of defense unavailable save one, he will be deemed to have elected that one." Id. (quoting Seegars v. State, 655 P.2d 563, 565 (Okla.Crim.App.1982); Jones v. State, 555 P.2d 1061, 1070 (Okla.Crim.App.1976)).

2010The Spuehler court held that the defendant was automatically barred from raising an inconsistent defense, reasoning that "[w]hen a defendant, who has a right of election as to several defenses, takes the stand as a witness and makes such admissions as to render every theory of defense unavailable save one, he will be deemed to have elected that one." Id. (quoting Seegars v. State, 655 P.2d 563, 565 (Okla.Crim.App.1982); Jones v. State, 555 P.2d 1061, 1070 (Okla.Crim.App.1976)).

11
People v. CALVARESTgreen
colo · 1975 · cited in 1 Colorado opinions naming this issue, 1996–1996
2 sentences

1996See id.; see also People v. Calvaresi, 188 Colo. 277, 282 , 534 P.2d 316, 318 (1975) ("A statute which prescribes different degrees of punishment for the same acts committed under like circumstances by persons in like situations is violative of a *1268 person's right to equal protection of the laws.").

1996See id.; see also People v. Calvaresi, 188 Colo. 277, 282 , 534 P.2d 316, 318 (1975) ("A statute which prescribes different degrees of punishment for the same acts committed under like circumstances by persons in like situations is violative of a *1268 person's right to equal protection of the laws.").

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Colorado. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Mathews v. United States green
scotus · 1988
2 sentences

2012While the supreme court's holding in Brown only addressed lesser included offenses, the division of this court deciding Brown, 218 P.3d 733 (Colo.App.2009), specifically addressed the United States Supreme Court's holding in Mathews v. United States, 485 U.S. 58, 63 , 108 S.Ct. 883 , 99 L.Ed.2d 54 (1988), that a defendant claiming complete innocence may also raise an inconsistent defense of entrapment.

2012While the supreme court's holding in Brown only addressed lesser included offenses, the division of this court deciding Brown, 218 P.3d 733 (Colo.App.2009), specifically addressed the United States Supreme Court's holding in Mathews v. United States, 485 U.S. 58, 63 , 108 S.Ct. 883 , 99 L.Ed.2d 54 (1988), that a defendant claiming complete innocence may also raise an inconsistent defense of entrapment.

22009–2012
People v. Gregoryd green
coloctapp · 1984
1 sentence

2024“Nor does the fact that a defendant may have an inconsistent defense necessarily entitle [her] to a separate trial.” Id.

12024–2024
Brown v. People green
colo · 2010
1 sentence

2018The supreme court decided that under the circumstances of Brown’s case, the principal policy arguments for denying the defendant his requested instruction — namely, “that allowing an inconsistent instruction would be contrary to ‘honesty and good faith’ and/or encourage perjury” — were “substantially mitigated.” Id. at 768-69 . ¶ 30 Here, the trial court viewed defendant’s assertions of both self- defense and accident as inconsistent.

12018–2018
People v. Brown green
coloctapp · 2009
2 sentences

2012While the supreme court's holding in Brown only addressed lesser included offenses, the division of this court deciding Brown, 218 P.3d 733 (Colo.App.2009), specifically addressed the United States Supreme Court's holding in Mathews v. United States, 485 U.S. 58, 63 , 108 S.Ct. 883 , 99 L.Ed.2d 54 (1988), that a defendant claiming complete innocence may also raise an inconsistent defense of entrapment.

2012The Brown division acknowledged prior precedent declining to follow Mathews, see Grizzle, 140 P.3d at 225-26 ; Hendrickson, 45 P.3d at 786 , and recognized Mathews was not binding because it addressed federal criminal law not rooted in the United States Constitution. 218 P.3d at 738 .

12012–2012
People v. Grizzle green
coloctapp · 2006
1 sentence

2012The Brown division acknowledged prior precedent declining to follow Mathews, see Grizzle, 140 P.3d at 225-26 ; Hendrickson, 45 P.3d at 786 , and recognized Mathews was not binding because it addressed federal criminal law not rooted in the United States Constitution. 218 P.3d at 738 .

12012–2012
People v. Hendrickson green
coloctapp · 2001
1 sentence

2012The Brown division acknowledged prior precedent declining to follow Mathews, see Grizzle, 140 P.3d at 225-26 ; Hendrickson, 45 P.3d at 786 , and recognized Mathews was not binding because it addressed federal criminal law not rooted in the United States Constitution. 218 P.3d at 738 .

12012–2012
Spuehler v. State green
oklacrimapp · 1985
2 sentences

2010The Spuchler court held that the defendant was automatically barred from raising an inconsistent defense, reasoning that "[when a defendant, who has a right of election as to several defenses, takes the stand as a witness and makes such admissions as to render every theory of defense unavailable save one, he will be deemed to have elected that one." Id. (quoting Seegars v. State, 655 P.2d 563, 565 (Okla.Crim.App.1982); Jones v. State, 555 P.2d 1061, 1070 (Okla.Crim.App.1976)).

2010The Spuehler court held that the defendant was automatically barred from raising an inconsistent defense, reasoning that "[w]hen a defendant, who has a right of election as to several defenses, takes the stand as a witness and makes such admissions as to render every theory of defense unavailable save one, he will be deemed to have elected that one." Id. (quoting Seegars v. State, 655 P.2d 563, 565 (Okla.Crim.App.1982); Jones v. State, 555 P.2d 1061, 1070 (Okla.Crim.App.1976)).

12010–2010
Eli B. Jones, of the Estate of Jesse L. Bobo, Deceased v. Federal Deposit Insurance Corporation, in Its Corporate Capacity green
ca10 · 1984
1 sentence

1999Jones v. Federal Deposit Insurance Corp., 748 F.2d 1400 (10th Cir.1984).

11999–1999
United States v. Charles Patrick Dill, Robert Eugene Brown, A/K/A Sidney Ray Griffin green
ca10 · 1982
1 sentence

1984United States v. Dill, supra. In addition, neither defendant took the stand, nor presented any evidence whatsoever.

11984–1984

Where else courts name it

NY 23 (1920–2024) CA 21 (1925–2024) IN 13 (1977–2025) WA 13 (1984–2026) GA 10 (1918–2021) TX 10 (1913–2022) FL 9 (1968–2021) CO 8 (1984–2024) MI 8 (1927–2024) NC 8 (1927–2002) MO 8 (1967–2019) MD 6 (1969–2016) IA 6 (1884–2015) CT 6 (1932–2010) KS 6 (1895–2024) OH 4 (1912–2025) NM 4 (1983–2019) AL 4 (1888–1983) IL 4 (1911–2016) NJ 3 (1973–2023) AZ 3 (1989–2023) MN 3 (1905–1987) PA 3 (2017–2024) KY 3 (1913–2025) OR 3 (1900–1987) WI 2 (2007–2011) MA 2 (1996–2025) NH 2 (1972–2018) OK 2 (1931–1985) NE 2 (1928–1982) WV 2 (1911–1999) SC 2 (1973–1986)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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