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Colorado Revised Statutes

Colo. Rev. Stat. § 16-10-108 (2026)

Verdict

✓ current as of July 2026
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The verdict of the jury shall be unanimous. The jury shall return its verdict in open court, but a sealed verdict may be received as provided by rule of the supreme court of Colorado.

Source: L. 72: R&RE, p. 238, § 1. C.R.S. 1963: § 39-10-108.

Notes of Decisions
Cited in 77 cases (11 in the last 5 years), 1981–2026 · leading case: People v. Bonvicini, 366 P.3d 151 (Colo. 2016).
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People v. Bonvicini, 366 P.3d 151 (Colo. 2016). · cites it 36× “Section 16-10-108(1) includes several grounds upon which either party in a criminal case may make a challenge for cause; 4 if *155 the proponent of a challenge demonstrates to the trial court that a potential juror falls within any of those categories, the statute implies their…”
Mulberger v. People, 366 P.3d 143 (Colo. 2016). · cites it 31× “" § 16-10-108(1)(k), CRS. (2015). At his trial for four driving offenses, petitioner Samuel J.”
People v. Novotny, 320 P.3d 1194 (Colo. 2014). · cites it 7× “See § 16-10-108(1)(a), C.R.S. (2018). Beyond the actual absence of some statutory qualification, the legislature has designated a number of other grounds that will also support a challenge for cause, generally involving such things as the prospective juror's relationship with…”
v. Dyer, 2019 COA 161 (Colo. Ct. App. 2019). · cites it 3× “¶ 54 Section 16-10-108, C.R.S. 2019, requires unanimous jury verdicts.”
People v. Asberry, 172 P.3d 927 (Colo. Ct. App. 2007). · cites it 5× “Fultz, supra, defense counsel did not apprise the court or the prosecutor that the court should not have excused the juror or that further action, like additional questioning, could have clarified whether the juror was disqualified from service by § 16-10-108(1)(c). A request…”
People v. Wagner, 2018 COA 68 (Colo. Ct. App. 2018). · cites it 2× “II, §§ 16, 25, and a unanimous jury verdict, § 16-10-108, C.R.S. 2017. “The trial court is responsible for ensuring that the jury is properly instructed on the law and that a conviction on any count is the result of a unanimous verdict.”
People v. Wilson, 356 P.3d 956 (Colo. Ct. App. 2014). · cites it 3× “T8 Section 16-10-108(1)(j), C.R.S.2018, and Crim.”
People v. Davis, 2017 COA 40M (Colo. Ct. App. 2017). · cites it 4× “§ 16-10-108, C.R.S. 2016; Crim. P. 23(a)(8), 31(a)(3); People v.”
People v. Honeysette, 53 P.3d 714 (Colo. Ct. App. 2002). · cites it 3× “Section 16-10-108(1)(j), C.R.S.2001. Under § 16-10-103(1)(j), the trial court must sustain a challenge for cause to a prospective Juror if the juror has a state of mind "evine-ing enmity or bias toward the defendant or the state.”
People v. Marquez, 692 P.2d 1089 (Colo. 1984). · cites it 6× “§ 16-10-108, 8 C.R.S. (1978); Crim.P. 23(a)(8) and 31(a)(3).”
Colorado v. Richardson, 184 P.3d 755 (Colo. 2008). · cites it 6× “See § 16-10-108, C.R.S. (2007); Crim. P. 23(a)(8); see also Hickey, 303 N.”
a v. People, 2020 CO 63M (Colo. 2020). · cites it 4× “§ 16-10-108, C.R.S. (2019); Crim. P. 23(a)(8); Crim.”
Show all 77 citing cases →
— Colo. Rev. Stat. § 16-10-108(1) — 14 cases
People v. Conyac, 361 P.3d 1005 (Colo. Ct. App. 2014).
People v. Arko, 159 P.3d 713 (Colo. Ct. App. 2006).
People v. Pasillas-Sanchez, 214 P.3d 520 (Colo. Ct. App. 2009).
People v. Dashner, 77 P.3d 787 (Colo. Ct. App. 2003).
People v. Cisneros, 356 P.3d 877 (Colo. Ct. App. 2014).
— Colo. Rev. Stat. § 16-10-108(1)(G) — 1 case
People v. Young, 16 P.3d 821 (Colo. 2001).
— Colo. Rev. Stat. § 16-10-108(1)(J) — 1 case
People v. Chavez, 313 P.3d 594 (Colo. Ct. App. 2011).
— Colo. Rev. Stat. § 16-10-108(1)(a) — 2 cases
People v. Novotny, 320 P.3d 1194 (Colo. 2014). “See § 16-10-108(1)(a), C.R.S. (2018). Beyond the actual absence of some statutory qualification, the legislature has designated a number of other grounds that will also support a challenge for cause, generally involving such things as the prospective juror's relationship with…”
People v. Lefebre, 5 P.3d 295 (Colo. 2000).
— Colo. Rev. Stat. § 16-10-108(1)(c) — 1 case
People v. Asberry, 172 P.3d 927 (Colo. Ct. App. 2007). “Fultz, supra, defense counsel did not apprise the court or the prosecutor that the court should not have excused the juror or that further action, like additional questioning, could have clarified whether the juror was disqualified from service by § 16-10-108(1)(c). A request…”
— Colo. Rev. Stat. § 16-10-108(1)(j) — 11 cases
People v. Wilson, 356 P.3d 956 (Colo. Ct. App. 2014). “T8 Section 16-10-108(1)(j), C.R.S.2018, and Crim.”
People v. Honeysette, 53 P.3d 714 (Colo. Ct. App. 2002). “Section 16-10-108(1)(j), C.R.S.2001. Under § 16-10-103(1)(j), the trial court must sustain a challenge for cause to a prospective Juror if the juror has a state of mind "evine-ing enmity or bias toward the defendant or the state.”
People v. Sherman, 45 P.3d 774 (Colo. Ct. App. 2001).
People v. Samuels, 228 P.3d 229 (Colo. Ct. App. 2009).
People v. Hoskay, 87 P.3d 194 (Colo. Ct. App. 2003).
— Colo. Rev. Stat. § 16-10-108(1)(k) — 11 cases
Mulberger v. People, 366 P.3d 143 (Colo. 2016). “" § 16-10-108(1)(k), CRS. (2015). At his trial for four driving offenses, petitioner Samuel J.”
People v. Bonvicini, 366 P.3d 151 (Colo. 2016). “Section 16-10-108(1) includes several grounds upon which either party in a criminal case may make a challenge for cause; 4 if *155 the proponent of a challenge demonstrates to the trial court that a potential juror falls within any of those categories, the statute implies their…”
People v. Novotny, 320 P.3d 1194 (Colo. 2014). “See § 16-10-108(1)(a), C.R.S. (2018). Beyond the actual absence of some statutory qualification, the legislature has designated a number of other grounds that will also support a challenge for cause, generally involving such things as the prospective juror's relationship with…”
People v. Asberry, 172 P.3d 927 (Colo. Ct. App. 2007). “Fultz, supra, defense counsel did not apprise the court or the prosecutor that the court should not have excused the juror or that further action, like additional questioning, could have clarified whether the juror was disqualified from service by § 16-10-108(1)(c). A request…”
People v. Sommerfeld, 214 P.3d 570 (Colo. Ct. App. 2009).
— Colo. Rev. Stat. § 16-10-108(2) — 1 case
People v. Novotny, 320 P.3d 1194 (Colo. 2014). “See § 16-10-108(1)(a), C.R.S. (2018). Beyond the actual absence of some statutory qualification, the legislature has designated a number of other grounds that will also support a challenge for cause, generally involving such things as the prospective juror's relationship with…”
— Colo. Rev. Stat. § 16-10-108(8) — 1 case
People v. Asberry, 172 P.3d 927 (Colo. Ct. App. 2007). “Fultz, supra, defense counsel did not apprise the court or the prosecutor that the court should not have excused the juror or that further action, like additional questioning, could have clarified whether the juror was disqualified from service by § 16-10-108(1)(c). A request…”
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