Workers’ Compensation —Personal Jurisdiction—Specific Jurisdiction.

In this case, the Supreme Court considered whether Colorado has jurisdiction to award benefits for out-of-state work-related injuries and impose a statutory penalty on an employer under CRS § 8-41-204 when the employer is not a citizen of Colorado and has no offices or operations in Colorado but hired a Colorado citizen within the state. The Court concluded that under the facts of this case, Colorado lacks personal jurisdiction over the employer and therefore the employer cannot be subject to the Workers’ Compensation Act of Colorado, CRS §§ 8-40-101 to 8-47-209. Accordingly, the Court reversed the judgment of the Court of Appeals.

Criminal Trials—Continuances—Speedy Trial.

Defendant sought review of the Court of Appeals’ judgment affirming his conviction and sentence for sexual assault on a child by one in a position of trust. See People v. Nagi, 2014 COA 12, ___ P.3d ___. In addition to rejecting his challenge to the legality of his sentence, the Court of Appeals rejected defendant’s assertion that he was denied his statutory right to a speedy trial, as prescribed by CRS § 18-1-405. Defendant had argued that the district court lacked sufficient grounds to justify ordering a competency evaluation, and that the period during which defendant was under observation or examination was therefore not properly excluded from the calculation of the time within which trial was statutorily required. With one member of the panel dissenting, the appellate court found that the district court did not abuse its discretion in ordering the evaluation, notwithstanding its reference to defendant’s choice to proceed pro se as at least one of the reasons for questioning his competency, and that the evaluation period was therefore properly excluded and defendant’s statutory speedy trial right was not violated.

The Supreme Court affirmed, holding that because CRS § 18-1-405, on its face, mandates exclusion from defendant’s speedy trial computation of any period during which he was actually being examined for competency, without regard for the necessity or propriety of the court’s order requiring such an examination, defendant was brought to trial within the statutorily calculated six-month period. In the absence of any specific assertion or indication in the record that the district court’s order was entered in bad faith, for the purpose of circumventing the statutory speedy trial mandate or otherwise depriving the defendant of a protected interest, rather than from any concern for defendant’s rights or the integrity of the judicial process, defendant’s right to a speedy trial was not violated.