Mendoza-Martinez factors (Colorado) · Go Syfert
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Mendoza-Martinez factors in Colorado

6 Colorado opinions name it 2 courts 2009–2026 3 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 (18)

CaseFollowedCited
Smith v. Doegreen
scotus · 2003 · cited in 2 Colorado opinions naming this issue, 2021–2026
2 sentences

2021This he cannot do." ) ; Vasquez v. Foxx , 895 F.3d 515, 520 ( 7th Cir. 2018 ) ( " SORNA 's registration regime for sex offenders is not penal in nature." ) ; Doe v. Miller , 405 F.3d 700, 723 ( 8th Cir. 2005 ) ( " [W] e conclude that the [ Appellees ] have not established the ‘clearest proof’ that Iowa's choice [in sex offender residency restrictions] is excessive in relation to its legitimate regulatory purpose, such that a statute designed to be nonpunitive and regulatory should be considered retroactive criminal punishment." ) ; Hatton v. Bonner , 356 F.3d 955, 967 ( 9th Cir. 2004 ) ( "When

2021This he cannot do." ) ; Vasquez v. Foxx , 895 F.3d 515, 520 ( 7th Cir. 2018 ) ( " SORNA 's registration regime for sex offenders is not penal in nature." ) ; Doe v. Miller , 405 F.3d 700, 723 ( 8th Cir. 2005 ) ( " [W] e conclude that the [ Appellees ] have not established the ‘clearest proof’ that Iowa's choice [in sex offender residency restrictions] is excessive in relation to its legitimate regulatory purpose, such that a statute designed to be nonpunitive and regulatory should be considered retroactive criminal punishment." ) ; Hatton v. Bonner , 356 F.3d 955, 967 ( 9th Cir. 2004 ) ( "When

12
People v. Steadgreen
coloctapp · 2002 · cited in 2 Colorado opinions naming this issue, 2013–2017
2 sentences

2017Mendoza-Martinez, 372 U.S. at 169 ; see also Rowland, 207 P.3d at 892 ; Stead, 66 P.3d at 120-21 . 1.

2017Mendoza-Martinez, 372 U.S. at 169 ; see also Rowland, 207 P.3d at 892 ; Stead, 66 P.3d at 120-21 . 1.

12
Millard v. Rankingreen
ca10 · 2020 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021In examining this factor of the Mendoza-Martinez test , we look to "whether CSORA 's registration requirements are ‘regarded in our history and traditions as a punishment.’ " Millard , 971 F.3d at 1182 ( quoting Smith , 538 U.S. at 97 , 123 S.Ct. 1140 ) .

11
In the Interest of Justin B.green
sc · 2017 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
In re Amendment to Rule 25, South Carolina Rules of Family Courtgreen
sc · 2017 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
Joshua Vasquez v. Kimberly Foxxgreen
ca7 · 2018 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021This he cannot do." ) ; Vasquez v. Foxx , 895 F.3d 515, 520 ( 7th Cir. 2018 ) ( " SORNA 's registration regime for sex offenders is not penal in nature." ) ; Doe v. Miller , 405 F.3d 700, 723 ( 8th Cir. 2005 ) ( " [W] e conclude that the [ Appellees ] have not established the ‘clearest proof’ that Iowa's choice [in sex offender residency restrictions] is excessive in relation to its legitimate regulatory purpose, such that a statute designed to be nonpunitive and regulatory should be considered retroactive criminal punishment." ) ; Hatton v. Bonner , 356 F.3d 955, 967 ( 9th Cir. 2004 ) ( "When

11
In Re JWgreen
ill · 2003 · cited in 1 Colorado opinions naming this issue, 2021–2021
2 sentences

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
People Ex Rel. Birkett v. Konetskigreen
ill · 2009 · cited in 1 Colorado opinions naming this issue, 2021–2021
2 sentences

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
In Re the Welfare of C.D.N.green
minnctapp · 1997 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
David Clinton Hatton v. Edward Bonnergreen
ca9 · 2004 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021This he cannot do." ) ; Vasquez v. Foxx , 895 F.3d 515, 520 ( 7th Cir. 2018 ) ( " SORNA 's registration regime for sex offenders is not penal in nature." ) ; Doe v. Miller , 405 F.3d 700, 723 ( 8th Cir. 2005 ) ( " [W] e conclude that the [ Appellees ] have not established the ‘clearest proof’ that Iowa's choice [in sex offender residency restrictions] is excessive in relation to its legitimate regulatory purpose, such that a statute designed to be nonpunitive and regulatory should be considered retroactive criminal punishment." ) ; Hatton v. Bonner , 356 F.3d 955, 967 ( 9th Cir. 2004 ) ( "When

11
Doe v. Millergreen
ca8 · 2005 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021This he cannot do." ) ; Vasquez v. Foxx , 895 F.3d 515, 520 ( 7th Cir. 2018 ) ( " SORNA 's registration regime for sex offenders is not penal in nature." ) ; Doe v. Miller , 405 F.3d 700, 723 ( 8th Cir. 2005 ) ( " [W] e conclude that the [ Appellees ] have not established the ‘clearest proof’ that Iowa's choice [in sex offender residency restrictions] is excessive in relation to its legitimate regulatory purpose, such that a statute designed to be nonpunitive and regulatory should be considered retroactive criminal punishment." ) ; Hatton v. Bonner , 356 F.3d 955, 967 ( 9th Cir. 2004 ) ( "When

11
Helman v. Stategreen
del · 2001 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
In Re the Welfare of J.R.Z.green
minnctapp · 2002 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
State v. Bochegreen
neb · 2016 · cited in 1 Colorado opinions naming this issue, 2021–2021
2 sentences

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
People v. J.C. (In re J.C.)green
calctapp5d · 2017 · cited in 1 Colorado opinions naming this issue, 2021–2021
2 sentences

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
Ronald S. Kammerer, Jr. v. The State of Wyominggreen
wyo · 2014 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

11
United States v. Wardgreen
scotus · 1980 · cited in 1 Colorado opinions naming this issue, 2021–2021
2 sentences

2021Mendoza-Martinez, 372 U.S. at 168 ; see also United States v. Ward, 448 U.S. 242, 249 (1980) (noting that the seven factors in Mendoza-Martinez are helpful considerations in determining whether Congress provided for 41 sanctions so punitive as to transform a civil remedy into a criminal penalty); People in Interest of T.B., ¶¶ 31-47 (applying the Mendoza- Martinez factors in its analysis of whether a statute created a punishment).

2021Mendoza-Martinez, 372 U.S. at 168 ; see also United States v. Ward, 448 U.S. 242, 249 (1980) (noting that the seven factors in Mendoza-Martinez are helpful considerations in determining whether Congress provided for 41 sanctions so punitive as to transform a civil remedy into a criminal penalty); People in Interest of T.B., ¶¶ 31-47 (applying the Mendoza- Martinez factors in its analysis of whether a statute created a punishment).

11
People v. Rowlandgreen
coloctapp · 2009 · cited in 1 Colorado opinions naming this issue, 2017–2017
2 sentences

2017Mendoza-Martinez, 372 U.S. at 169 ; see also Rowland, 207 P.3d at 892 ; Stead, 66 P.3d at 120-21 . 1.

2017Mendoza-Martinez, 372 U.S. at 169 ; see also Rowland, 207 P.3d at 892 ; Stead, 66 P.3d at 120-21 . 1.

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 (10)

CaseCitedYears
Kennedy v. Mendoza-Martinez green
scotus · 1963
2 sentences

2026Thus, we see these measures as civil regulatory means principally designed to keep a community safe by ensuring that community members can take the steps needed to keep themselves safe. ¶52 Finally, both the sixth and seventh Mendoza-Martinez factors—whether a measure is rationally related to a nonpunitive purpose and is not excessive regarding that purpose—weigh against considering the SVP designation as punishment. [11] 372 U.S. at 168-69 .

2021Mendoza-Martinez, 372 U.S. at 168 ; see also United States v. Ward, 448 U.S. 242, 249 (1980) (noting that the seven factors in Mendoza-Martinez are helpful considerations in determining whether Congress provided for 41 sanctions so punitive as to transform a civil remedy into a criminal penalty); People in Interest of T.B., ¶¶ 31-47 (applying the Mendoza- Martinez factors in its analysis of whether a statute created a punishment).

52009–2026
Allen v. People green
colo · 2013
2 sentences

2026Controls This Analysis ¶30 Beagle challenges the division's reliance on Allen , which stated that the SVP designation "is not punishment," ¶ 7, 307 P.3d at 1105 , to hold that the SVP designation was not punishment; he points out that Allen did not involve an Eighth Amendment challenge and thus did not implicate the Mendoza-Martinez factors.

2026Controls This Analysis ¶30 Beagle challenges the division's reliance on Allen , which stated that the SVP designation "is not punishment," ¶ 7, 307 P.3d at 1105 , to hold that the SVP designation was not punishment; he points out that Allen did not involve an Eighth Amendment challenge and thus did not implicate the Mendoza-Martinez factors.

12026–2026
The PEOPLE of the State of Colorado, Petitioner/Cross-Respondent, IN the INTEREST OF T.B., Respondent/Cross-Petitioner green
colo · 2021
2 sentences

2026First, T.B. analyzed lifetime sex-offender registration as applied to juveniles . ¶ 2, 489 P.3d at 755-56 .

2026First, as we acknowledged in T.B. , there are ways that the sex-offender registration and community notification programs here resemble a historical form of punishment—namely, public shaming and humiliation. ¶ 52, 489 P.3d at 767 . 20 ¶39 Specifically, Beagle maintains that community notification via a town-hall meeting resembles public shaming. [9] And, in its amicus brief, the American Civil Liberties Union of Colorado ("ACLU") takes issue with the alternative to a townhall meeting most often employed by localities, where police departments publish the required information to their Facebook

12026–2026
Roper v. Simmons green
scotus · 2005
2 sentences

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

12021–2021
People v. Jaso green
coloctapp · 2014
2 sentences

2021And we agree that the Mendoza-Martinez factors were the appropriate analytical framework to determine whether a domestic violence finding is a penalty. ¶ 82 In addition, we reject Pellegrin’s reliance on People v. Jaso, 2014 COA 131 .

2021And we agree that the Mendoza-Martinez factors were the appropriate analytical framework to determine whether a domestic violence finding is a penalty. ¶ 82 In addition, we reject Pellegrin’s reliance on People v. Jaso, 2014 COA 131 .

12021–2021
People v. Smoots green
coloctapp · 2013
2 sentences

2021He therefore declined to revisit all but one of the Mendoza-Martinez factors : "whether the sanction appears excessive in relation to the alternative purposes assigned." Id. at ¶ 71 . ¶23 As for that factor, Judge Webb articulated three reasons for concluding that CSORA 's registration requirement is not an excessive sanction.

2021He therefore declined to revisit all but one of the Mendoza-Martinez factors : "whether the sanction appears excessive in relation to the alternative purposes assigned." Id. at ¶ 71 . ¶23 As for that factor, Judge Webb articulated three reasons for concluding that CSORA 's registration requirement is not an excessive sanction.

12021–2021
Kansas v. Hendricks green
scotus · 1997
2 sentences

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

2021See, e.g. , In Int. of Justin B. , 419 S.C. 575 , 799 S.E.2d 675, 681 ( 2017 ) ( "The requirement that adults and juveniles who commit criminal sexual conduct must register as a sex offender and wear an electronic monitor is not a punitive measure, and the requirement bears a rational relationship to the Legislature 's purpose ...." ( emphasis added ) ) ; State v. Boche , 294 Neb. 912 , 885 N.W.2d 523, 532 ( 2016 ) ( "Because we conclude the lifetime registration requirements imposed on [the juvenile] are not punishment, his argument that these registration requirements amount to cruel and unu

12021–2021
People v. Milton green
colo · 1987
2 sentences

2017We recognize that the domestic violence treatment program “is not without [some] burdensome consequences to the [defendant],” in terms of cost and duration, but “[treatment] is primarily directed toward achieving the salutary goal of preventing and terminating [domestic violence],” Milton, 732 P.2d at 1204 , and therefore does not impose an excessive burden on defendants. ¶ 63 In conclusion, the Mendoza-Martinez analysis indicates that court-ordered domestic violence treatment, based on a trial court’s 26 finding of domestic violence under section 18-6-801(1)(a), does not impose a punishment a

2017We recognize that the domestic violence treatment program “is not without [some] burdensome consequences to the [defendant],” in terms of cost and duration, but “[treatment] is primarily directed toward achieving the salutary goal of preventing and terminating [domestic violence],” Milton, 732 P.2d at 1204 , and therefore does not impose an excessive burden on defendants. ¶ 63 In conclusion, the Mendoza-Martinez analysis indicates that court-ordered domestic violence treatment, based on a trial court’s 26 finding of domestic violence under section 18-6-801(1)(a), does not impose a punishment a

12017–2017
Alleyne v. United States green
· 2013
2 sentences

2017Therefore, we conclude that the statute is not facially unconstitutional under Alleyne, 570 U.S. at __ , 133 S. Ct. at 2155 .

2017Therefore, we conclude that the statute is not facially unconstitutional under Alleyne, 570 U.S. at __ , 133 S. Ct. at 2155 .

12017–2017
Apprendi v. New Jersey green
scotus · 2000
2 sentences

2013This conclusion arose during the court of appeals' application of the "scienter'" factor of "the Mendoza-Martinez test" delineated by the United States Supreme Court for the purposes of classifying a statutory scheme as "punishment" under Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000).

2013This conclusion arose during the court of appeals' application of the "scienter'" factor of "the Mendoza-Martinez test" delineated by the United States Supreme Court for the purposes of classifying a statutory scheme as "punishment" under Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000).

12013–2013

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 18-3-414.5 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 65 (2003–2026) IL 19 (1992–2021) CA 17 (1999–2021) MI 16 (2014–2026) AZ 8 (1991–2020) IN 8 (2009–2019) WI 7 (2002–2021) ME 7 (2001–2015) CO 6 (2009–2026) KS 6 (1996–2017) IA 6 (1997–2021) MD 6 (1998–2020) NM 6 (2003–2015) NC 6 (2007–2010) WA 5 (1994–2023) OR 5 (1977–2024) NJ 4 (1995–2014) ND 4 (1999–1999) OH 4 (1998–2008) LA 3 (1987–2025) NY 3 (1988–2010) DC 2 (2004–2004) WV 2 (1992–2020) MN 2 (2014–2017) MA 2 (1996–2009) SC 2 (2013–2014) KY 2 (2010–2010) OK 2 (2013–2025) GA 2 (2018–2018) AL 2 (2004–2011) MT 2 (2003–2005) NV 2 (2013–2013) MS 2 (2005–2006)

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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