Brooks v. ColoradoAnnotate this Case
After a jury found Kyle Brooks guilty of two class 4 felonies for victim tampering, the trial court adjudicated him to be a habitual criminal based on his prior felony convictions, including his guilty plea to theft from a person. The trial court sentenced him to twenty-four years in prison. Brooks claimed on appeal to the Colorado Supreme Court that his prior theft from a person conviction was constitutionally invalid. Therefore, the issue presented to the Supreme Court was whether the trial record established by a preponderance of the evidence whether Brooks understood the elements of theft from a person when he previously pleaded guilty. The Court concluded that it did, and accordingly, held Brooks’ prior guilty plea to theft from a person was constitutionally valid.