Colo. Rev. Stat. » Title 16
Colorado Revised Statutes

Colo. Rev. Stat. § 16-10-103 (2026)

Challenge of jurors for cause

✓ current as of July 2026
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(1) The court shall sustain a challenge for cause on one or more of the following grounds:

(a) Absence of any qualification prescribed by statute to render a person competent as a juror;

(b) Relationship within the third degree, by blood, adoption, or marriage, to a defendant or to any attorney of record or attorney engaged in the trial of the case;

(c) Standing in the relation of guardian and ward, employer and employee, landlord and tenant, debtor and creditor, or principal and agent to, or being a member of the household of, or a partner in business with, or surety on any bond or obligation for any defendant;

(d) The juror is or has been a party adverse to the defendant in a civil action or has complained against or been accused by him in a criminal prosecution;

(e) The juror has served on the grand jury which returned the indictment, or on a coroner's jury which inquired into the death of a person whose death is the subject of the indictment or information, or on any other investigatory body which inquired into the facts of the crime charged;

(f) The juror was a juror at a former trial arising out of the same factual situation or involving the same defendant;

(g) The juror was a juror in a civil action against the defendant arising out of the act charged as a crime;

(h) The juror was a witness to any matter related to the crime or its prosecution;

(i) The juror occupies a fiduciary relationship to the defendant or a person alleged to have been injured by the crime or the person on whose complaint the prosecution was instituted;

(j) The existence of a state of mind in the juror evincing enmity or bias toward the defendant or the state; however, no person summoned as a juror shall be disqualified by reason of a previously formed or expressed opinion with reference to the guilt or innocence of the accused, if the court is satisfied, from the examination of the juror or from other evidence, that he will render an impartial verdict according to the law and the evidence submitted to the jury at the trial;

(k) The juror is a compensated employee of a public law enforcement agency or a public defender's office.

(2) If any juror knows of anything which would disqualify him as a juror or be a ground for challenge to him for cause, it is his duty to inform the court concerning it whether or not he is specifically asked about it. The jury panel shall be advised of this duty and of the grounds for challenge for cause before any prospective jurors are called to the jury box.

(3) If either party desires to introduce evidence of the incompetency, disqualification, or prejudice of any prospective juror who upon the voir dire examination appears to be qualified, competent, and unprejudiced, such evidence shall be heard, and the competency of the juror shall be determined, by the court, out of the presence of the other jurors, but this action cannot be taken after the jury has been sworn to try the case except upon a motion for mistrial. Source: L. 72: R&RE, p. 236, § 1. C.R.S. 1963: § 39-10-103. L. 98: (1)(k) amended, p. 466, § 6, effective January 1, 1999.

Notes of Decisions
Cited in 164 cases (29 in the last 5 years), 1976–2026 · leading case: v. Abu-Nantambu-El, 2019 CO 106 (Colo. 2019).
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v. Abu-Nantambu-El, 2019 CO 106 (Colo. 2019). · cites it 58× “He rejected Judge Booras’s express legislative mandate approach because section 16-10-103 is silent on the remedy for the seating of a biased juror.”
Ma v. People, 121 P.3d 205 (Colo. 2005). · cites it 50× “II, § 16, a trial court in a criminal case must grant all valid challenges for cause, see § 16-10-103; Carrillo v. People, 974 P.2d 478, 486-87 (Colo.”
v. People, 2019 CO 105 (Colo. 2019). · cites it 12× “§ 16-10-103(1)(a), C.R.S. (2019). Beyond the actual absence of some statutory qualification, however, the legislature has enumerated a number of other grounds that will also support a challenge for cause in criminal cases, broadly involving circumstances implicating a…”
People v. Veloz, 946 P.2d 525 (Colo. Ct. App. 1997). · cites it 60× “The circumstances under which a prospective juror will be disqualified from jury service on the basis of a bias "attributable in law to a prospective juror regardless of actual partiality" are limited to those expressly delineated by the General Assembly in § 16-10-103(1),…”
People v. Rhodus, 870 P.2d 470 (Colo. 1994). · cites it 30× “II Rhodus contends that the relationship between Hatfield and the district attorney’s office created an implied bias and therefore the trial court should have granted Rhodus’ challenge for cause.”
Binkley v. People, 716 P.2d 1111 (Colo. 1986). · cites it 25× “Since the legislature did not define the word “lawyer” in section 16-10-103, 8 C.R.S. (1978), we look first to the commonly accepted meaning of that term.”
People v. Novotny, 320 P.3d 1194 (Colo. 2014). · cites it 7× “It states that the court shall sustain a challenge for cause on the following ground: ''The existence of a state of mind in the juror evincing enmity or bias toward the defendant or the state; however, no person summoned as a juror shall be disqualified by reason of a previously…”
People v. Speer, 255 P.3d 1115 (Colo. 2011). · cites it 17× “Because neither the Department of Homeland Security (DHS) nor the Transportation Security Administration (TSA) is a public law enforcement agency within the meaning of subsection 16-10-103(1)(k), C.R.S. (2010), the district court also did not err in rejecting the defendant's…”
People v. Cevallos-Acosta, 140 P.3d 116 (Colo. Ct. App. 2005). · cites it 6× “2004) (citing § 16-10-103(1)(j), C.R.S.2005). But expression of a possible source of bias does not require dismissal where the prospective juror agrees to set aside any preconceived notions and make a decision based on the evidence and the court’s instructions.”
People v. Frantz, 114 P.3d 34 (Colo. Ct. App. 2005). · cites it 7× “Section 16-10-103(1), C.R.S.2003; People v.”
on v. People, 2020 CO 46 (Colo. 2020). · cites it 3× “” And in discussing jury instructions, defense counsel quipped, “The instruction I gave to you and not the provocation? I’m just joking.”
People v. Russo, 713 P.2d 356 (Colo. 1986). · cites it 14× “(1978), provides as follows: (1) The court shall sustain a challenge for cause on one or more of the following grounds: (a) Absence of any qualification prescribed by statute to render a person competent as a juror; [6] *361 (b) Relationship within the third degree, by blood,…”
Show all 164 citing cases →
— Colo. Rev. Stat. § 16-10-103(0)(G) — 1 case
Morrison v. People, 19 P.3d 668 (Colo. 2000).
— Colo. Rev. Stat. § 16-10-103(1) — 46 cases
v. Abu-Nantambu-El, 2019 CO 106 (Colo. 2019). “He rejected Judge Booras’s express legislative mandate approach because section 16-10-103 is silent on the remedy for the seating of a biased juror.”
People v. Frantz, 114 P.3d 34 (Colo. Ct. App. 2005). “Section 16-10-103(1), C.R.S.2003; People v.”
People v. Rhodus, 870 P.2d 470 (Colo. 1994). “II Rhodus contends that the relationship between Hatfield and the district attorney’s office created an implied bias and therefore the trial court should have granted Rhodus’ challenge for cause.”
People v. Russo, 713 P.2d 356 (Colo. 1986). “(1978), provides as follows: (1) The court shall sustain a challenge for cause on one or more of the following grounds: (a) Absence of any qualification prescribed by statute to render a person competent as a juror; [6] *361 (b) Relationship within the third degree, by blood,…”
People v. Daniels, 973 P.2d 641 (Colo. Ct. App. 1998).
— Colo. Rev. Stat. § 16-10-103(1)(G) — 1 case
People v. RABES, 258 P.3d 937 (Colo. Ct. App. 2011).
— Colo. Rev. Stat. § 16-10-103(1)(a) — 4 cases
v. People, 2019 CO 105 (Colo. 2019). “§ 16-10-103(1)(a), C.R.S. (2019). Beyond the actual absence of some statutory qualification, however, the legislature has enumerated a number of other grounds that will also support a challenge for cause in criminal cases, broadly involving circumstances implicating a…”
People v. Pasillas-Sanchez, 214 P.3d 520 (Colo. Ct. App. 2009).
People v. Lefebre, 5 P.3d 295 (Colo. 2000).
People v. Orozco, 49 P.3d 1212 (Colo. Ct. App. 2002).
— Colo. Rev. Stat. § 16-10-103(1)(b) — 7 cases
on v. People, 2020 CO 46 (Colo. 2020). “” And in discussing jury instructions, defense counsel quipped, “The instruction I gave to you and not the provocation? I’m just joking.”
v. Abu-Nantambu-El, 2019 CO 106 (Colo. 2019). “He rejected Judge Booras’s express legislative mandate approach because section 16-10-103 is silent on the remedy for the seating of a biased juror.”
v. Richardson, 2018 COA 120 (Colo. Ct. App. 2018).
People v. Fleischacker, 411 P.3d 20 (Colo. Ct. App. 2013).
People v. MacRander, 828 P.2d 234 (Colo. 1992).
— Colo. Rev. Stat. § 16-10-103(1)(c) — 1 case
People v. Asberry, 172 P.3d 927 (Colo. Ct. App. 2007).
— Colo. Rev. Stat. § 16-10-103(1)(e) — 1 case
People v. Russo, 713 P.2d 356 (Colo. 1986). “(1978), provides as follows: (1) The court shall sustain a challenge for cause on one or more of the following grounds: (a) Absence of any qualification prescribed by statute to render a person competent as a juror; [6] *361 (b) Relationship within the third degree, by blood,…”
— Colo. Rev. Stat. § 16-10-103(1)(i) — 1 case
People v. Scott, 583 P.2d 939 (Colo. Ct. App. 1978).
— Colo. Rev. Stat. § 16-10-103(1)(j) — 71 cases
v. People, 2019 CO 105 (Colo. 2019). “§ 16-10-103(1)(a), C.R.S. (2019). Beyond the actual absence of some statutory qualification, however, the legislature has enumerated a number of other grounds that will also support a challenge for cause in criminal cases, broadly involving circumstances implicating a…”
v. Abu-Nantambu-El, 2019 CO 106 (Colo. 2019). “He rejected Judge Booras’s express legislative mandate approach because section 16-10-103 is silent on the remedy for the seating of a biased juror.”
People v. Novotny, 320 P.3d 1194 (Colo. 2014). “It states that the court shall sustain a challenge for cause on the following ground: ''The existence of a state of mind in the juror evincing enmity or bias toward the defendant or the state; however, no person summoned as a juror shall be disqualified by reason of a previously…”
v. Ambrose, 2021 COA 62 (Colo. Ct. App. 2021).
People v. Conyac, 361 P.3d 1005 (Colo. Ct. App. 2014).
— Colo. Rev. Stat. § 16-10-103(1)(k) — 31 cases
v. Abu-Nantambu-El, 2019 CO 106 (Colo. 2019). “He rejected Judge Booras’s express legislative mandate approach because section 16-10-103 is silent on the remedy for the seating of a biased juror.”
Ma v. People, 121 P.3d 205 (Colo. 2005). “II, § 16, a trial court in a criminal case must grant all valid challenges for cause, see § 16-10-103; Carrillo v. People, 974 P.2d 478, 486-87 (Colo.”
People v. Speer, 255 P.3d 1115 (Colo. 2011). “Because neither the Department of Homeland Security (DHS) nor the Transportation Security Administration (TSA) is a public law enforcement agency within the meaning of subsection 16-10-103(1)(k), C.R.S. (2010), the district court also did not err in rejecting the defendant's…”
People v. Veloz, 946 P.2d 525 (Colo. Ct. App. 1997). “The circumstances under which a prospective juror will be disqualified from jury service on the basis of a bias "attributable in law to a prospective juror regardless of actual partiality" are limited to those expressly delineated by the General Assembly in § 16-10-103(1),…”
Binkley v. People, 716 P.2d 1111 (Colo. 1986). “Since the legislature did not define the word “lawyer” in section 16-10-103, 8 C.R.S. (1978), we look first to the commonly accepted meaning of that term.”
— Colo. Rev. Stat. § 16-10-103(2) — 1 case
People v. Reddick, 610 P.2d 1359 (Colo. Ct. App. 1980).
— Colo. Rev. Stat. § 16-10-103(3) — 2 cases
People v. Garcia, 964 P.2d 619 (Colo. Ct. App. 1998).
People v. Beeman, 551 P.2d 726 (Colo. Ct. App. 1976).
— Colo. Rev. Stat. § 16-10-103(8) — 3 cases
People v. Asberry, 172 P.3d 927 (Colo. Ct. App. 2007).
People v. Novotny, 320 P.3d 1194 (Colo. 2014). “It states that the court shall sustain a challenge for cause on the following ground: ''The existence of a state of mind in the juror evincing enmity or bias toward the defendant or the state; however, no person summoned as a juror shall be disqualified by reason of a previously…”
People v. Mumford, 275 P.3d 667 (Colo. Ct. App. 2010).
— Colo. Rev. Stat. § 16-10-103(a) — 1 case
People v. Crespin, 635 P.2d 918 (Colo. Ct. App. 1981).
— Colo. Rev. Stat. § 16-10-103(j) — 3 cases
Beeman v. People, 565 P.2d 1340 (Colo. 1977).
People v. Vecchiarelli-McLaughlin, 984 P.2d 72 (Colo. 1999).
People v. Clemens, 417 P.3d 833 (Colo. Ct. App. 2013).
— Colo. Rev. Stat. § 16-10-103(l)(a) — 2 cases
People v. Speer, 216 P.3d 18 (Colo. Ct. App. 2008).
People v. Reddick, 610 P.2d 1359 (Colo. Ct. App. 1980).
— Colo. Rev. Stat. § 16-10-103(l)(b) — 4 cases
People v. Rhodus, 870 P.2d 470 (Colo. 1994). “II Rhodus contends that the relationship between Hatfield and the district attorney’s office created an implied bias and therefore the trial court should have granted Rhodus’ challenge for cause.”
Morales-Guevara v. Koren, 405 P.3d 262 (Colo. Ct. App. 2014).
People v. MacRander, 828 P.2d 234 (Colo. 1992).
People Colorado v. Macrander, 817 P.2d 579 (Colo. Ct. App. 1991).
— Colo. Rev. Stat. § 16-10-103(l)(e) — 1 case
People v. Russo, 713 P.2d 356 (Colo. 1986). “(1978), provides as follows: (1) The court shall sustain a challenge for cause on one or more of the following grounds: (a) Absence of any qualification prescribed by statute to render a person competent as a juror; [6] *361 (b) Relationship within the third degree, by blood,…”
— Colo. Rev. Stat. § 16-10-103(l)(j) — 14 cases
People v. Dore, 997 P.2d 1214 (Colo. Ct. App. 1999).
People v. Richardson, 58 P.3d 1039 (Colo. Ct. App. 2002).
People v. Rodriguez, 914 P.2d 230 (Colo. 1996).
People v. Loscutoff, 661 P.2d 274 (Colo. 1983).
People v. Gurule, 628 P.2d 99 (Colo. 1981).
— Colo. Rev. Stat. § 16-10-103(l)(k) — 15 cases
Ma v. People, 121 P.3d 205 (Colo. 2005). “II, § 16, a trial court in a criminal case must grant all valid challenges for cause, see § 16-10-103; Carrillo v. People, 974 P.2d 478, 486-87 (Colo.”
People v. Veloz, 946 P.2d 525 (Colo. Ct. App. 1997). “The circumstances under which a prospective juror will be disqualified from jury service on the basis of a bias "attributable in law to a prospective juror regardless of actual partiality" are limited to those expressly delineated by the General Assembly in § 16-10-103(1),…”
People v. Carter, 402 P.3d 480 (Colo. Ct. App. 2015).
Binkley v. People, 716 P.2d 1111 (Colo. 1986). “Since the legislature did not define the word “lawyer” in section 16-10-103, 8 C.R.S. (1978), we look first to the commonly accepted meaning of that term.”
People v. Speer, 216 P.3d 18 (Colo. Ct. App. 2008).
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