Archuleta v. Colorado
Annotate this CaseIn this tragic case involving a charge of child abuse resulting in death, the issue presented for the Colorado Supreme Court's review centered on whether the defendant Sandra Archuleta was entitled to a modified unanimity instruction requiring jurors either unanimously agree that she committed the same act or acts underlying the child abuse charge or that she committed all of those acts. The prosecution charged and tried this case on the theory that Archuleta had committed the offense at issue by engaging in a single criminal transaction resulting in the child’s death. In light of the prosecution’s theory, the Supreme Court found no reasonable likelihood that the jurors disagreed on which specific act caused the child’s death, therefore, Archuleta was not entitled to a modified unanimity instruction here. The Supreme Court reversed the court of appeals judgment to the contrary, and remanded for consideration of Archuleta’s remaining contentions on appeal.
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