jury on an affirmative defense (Colorado) · Go Syfert
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jury on an affirmative defense in Colorado

5 Colorado opinions name it 1 courts 2008–2026 4 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 (6)

CaseFollowedCited
Cassels v. Peoplegreen
colo · 2004 · cited in 1 Colorado opinions naming this issue, 2026–2026
1 sentence

2026But while we review for an abuse of discretion whether a court erred by refusing to give a particular instruction, a court may abuse its discretion in this context if it misapplies the law, People v. Maloy, 2020 COA 71, ¶ 54 , and when, as in this case, the defendant asserts a misapplication of the law, we review that embedded question of law de novo, see People v. Dominguez, 2019 COA 78, ¶ 13 . 13 ¶ 29 But the test for determining whether a defendant is entitled to a provocation instruction is the same as it is for instructing the jury on an affirmative defense: “A provocation instruction is

11
People v. Sepulvedagreen
colo · 2003 · cited in 1 Colorado opinions naming this issue, 2026–2026
1 sentence

2026But while we review for an abuse of discretion whether a court erred by refusing to give a particular instruction, a court may abuse its discretion in this context if it misapplies the law, People v. Maloy, 2020 COA 71, ¶ 54 , and when, as in this case, the defendant asserts a misapplication of the law, we review that embedded question of law de novo, see People v. Dominguez, 2019 COA 78, ¶ 13 . 13 ¶ 29 But the test for determining whether a defendant is entitled to a provocation instruction is the same as it is for instructing the jury on an affirmative defense: “A provocation instruction is

11
People v. Speergreen
colo · 2011 · cited in 1 Colorado opinions naming this issue, 2024–2024
1 sentence

2024The court needs to instruct the jury on an affirmative defense “only if some evidence presented at trial supports it and the defendant requests it.” People v. Lee, 30 P.3d 686, 689 (Colo. App. 2000) (emphasis added); see also People v. Speer, 255 P.3d 1115, 1119 (Colo. 2011) (“[A] trial court is obliged to instruct the jury on a requested affirmative defense if there is any credible evidence . . . supporting it.”) (emphasis added). ¶ 25 Lewis cites no authority, and we’ve located none, for the proposition that his counsel’s request during his first trial for an instruction on the defense of us

11
People v. Leegreen
coloctapp · 2000 · cited in 1 Colorado opinions naming this issue, 2024–2024
1 sentence

2024The court needs to instruct the jury on an affirmative defense “only if some evidence presented at trial supports it and the defendant requests it.” People v. Lee, 30 P.3d 686, 689 (Colo. App. 2000) (emphasis added); see also People v. Speer, 255 P.3d 1115, 1119 (Colo. 2011) (“[A] trial court is obliged to instruct the jury on a requested affirmative defense if there is any credible evidence . . . supporting it.”) (emphasis added). ¶ 25 Lewis cites no authority, and we’ve located none, for the proposition that his counsel’s request during his first trial for an instruction on the defense of us

11
Griego v. Peoplegreen
colo · 2001 · cited in 1 Colorado opinions naming this issue, 2023–2023
1 sentence

2023Although Hagos didn’t involve an alleged failure to instruct the jury on an affirmative defense, the supreme court has more recently held that an error in failing to instruct the jury on an affirmative defense “is subject to constitutional harmless error review.” Pearson, ¶ 16; see also Griego v. People, 19 P.3d 1, 8 (Colo. 2001) (holding that “when a trial court misinstructs the jury on an element of an offense, either by omitting or misdescribing that element, that error is subject to constitutional harmless” error review). ¶ 54 We will assume, without deciding, that we should review for con

11
People v. Fullergreen
colo · 1989 · cited in 1 Colorado opinions naming this issue, 2008–2008
1 sentence

2008See, eg., People v. Fuller, 781 P.2d 647, 651 (Colo.1989) (self-defense).

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 (4)

CaseCitedYears
v. Dominguez green
coloctapp · 2019
1 sentence

2026But while we review for an abuse of discretion whether a court erred by refusing to give a particular instruction, a court may abuse its discretion in this context if it misapplies the law, People v. Maloy, 2020 COA 71, ¶ 54 , and when, as in this case, the defendant asserts a misapplication of the law, we review that embedded question of law de novo, see People v. Dominguez, 2019 COA 78, ¶ 13 . 13 ¶ 29 But the test for determining whether a defendant is entitled to a provocation instruction is the same as it is for instructing the jury on an affirmative defense: “A provocation instruction is

12026–2026
v. Maloy green
coloctapp · 2020
1 sentence

2026But while we review for an abuse of discretion whether a court erred by refusing to give a particular instruction, a court may abuse its discretion in this context if it misapplies the law, People v. Maloy, 2020 COA 71, ¶ 54 , and when, as in this case, the defendant asserts a misapplication of the law, we review that embedded question of law de novo, see People v. Dominguez, 2019 COA 78, ¶ 13 . 13 ¶ 29 But the test for determining whether a defendant is entitled to a provocation instruction is the same as it is for instructing the jury on an affirmative defense: “A provocation instruction is

12026–2026
Hagos v. People green
colo · 2012
1 sentence

2025Hagos v. People, 2012 CO 63 , ¶ 11; Coahran, ¶ 16 (“If a trial court refuses to give an affirmative defense self- defense instruction in circumstances where one was appropriate, . . . [t]his error implicates a defendant’s constitutional rights and is reviewed for constitutional harmless error.”). ¶ 12 A trial court should instruct the jury on an affirmative defense if “some credible evidence” supports the defense. § 18-1-407(1), C.R.S. 2025; Pearson v. People, 2022 CO 4, ¶ 16 .

12025–2025
Thomas Pearson v. The People of the State of Colorado. green
colo · 2022
1 sentence

2025Hagos v. People, 2012 CO 63 , ¶ 11; Coahran, ¶ 16 (“If a trial court refuses to give an affirmative defense self- defense instruction in circumstances where one was appropriate, . . . [t]his error implicates a defendant’s constitutional rights and is reviewed for constitutional harmless error.”). ¶ 12 A trial court should instruct the jury on an affirmative defense if “some credible evidence” supports the defense. § 18-1-407(1), C.R.S. 2025; Pearson v. People, 2022 CO 4, ¶ 16 .

12025–2025

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 18-1-407 (3) CO § Colo. Rev. Stat. § 18-1-704 (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

OH 14 (2002–2026) IL 11 (2006–2020) WA 10 (2013–2025) FL 7 (1973–2026) CO 5 (2008–2026) NY 4 (1995–2014) NJ 4 (2016–2024) CA 3 (2015–2026) MI 2 (2019–2019) NC 2 (2014–2014) GA 2 (2006–2010) TX 2 (1934–2018) CT 2 (1990–1997)

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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