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Colorado Supreme Court Opinions
October 15, 2013

2013 CO 59. No. 11SC801. People v. Jones.
CRE 404(b)—Doctrine of Chances—Spoto Analysis.

The Supreme Court held that trial courts have no obligation to determine that evidence of other acts offered under CRE 404(b) and CRS § 16-10-301 satisfies the doctrine of chances and the second and third prongs of the four-part admissibility test articulated in People v. Spoto, 795 P.2d 1314, 1318 (Colo. 1990). Although the doctrine of chances provides one theory pursuant to which other acts evidence may satisfy these two components of the Spoto analysis, trial courts have discretion to assess the relevance of other acts evidence under Spoto apart from the doctrine of chances. The court of appeals therefore erred when it held that the trial court abused its discretion by admitting other acts evidence without conducting a doctrine of chances analysis.

Colorado Supreme Court Opinions

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