Colorado v. Donald
Annotate this CaseAfter Laron Donald was arrested and charged with a felony, the district court set bond and announced the next court date. Donald subsequently posted bond and was released from jail. The one-page bond provided that as a condition of his release, Donald was prohibited from leaving the state of Colorado without approval of the court and the surety. Donald failed to appear at his next scheduled court date, and the court issued a warrant for his arrest. Five weeks later, Donald was pulled over for a traffic violation in Mississippi; the officer discovered Donald had outstanding Colorado warrants and arrested him. Donald was subsequently extradited to Colorado and charged with several counts of violation of bail bond conditions under section 18-8-212(1), C.R.S. (2019). The issue his case presented for the Colorado Supreme Court's review centered on: (1) what role, if any, the prohibition on inference stacking set out in Tate v. Colorado, 247 P.2d 665 (Colo. 1952), should play in sufficiency of the evidence challenges in criminal cases; and (2) whether sufficient evidence supported Donald’s conviction for violation of bail bond conditions. After review of the specific facts of this case, the Supreme Court concluded: (1) the presence of stacked inferences was not alone dispositive of a sufficiency of the evidence claim (it is one factor that a court may consider in determining whether the evidence presented satisfied the prevailing substantial evidence test for evidence sufficiency); and (2) the prosecution here presented sufficient evidence to support Donald’s conviction for violating the bail bond condition prohibiting him from leaving the state without permission. Accordingly, judgment of the division below was reversed and the matter remanded for further proceedings.
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