Laeke v. Colorado
Annotate this CaseRespondent Abel Laeke was charged with one count of criminal attempt to commit unlawful sexual contact and one count of indecent exposure as a result of events that the State alleged occurred while he was a patient at the psychiatric ward at Denver Health Medical Center in 2004. At a preliminary hearing, the county court found probable cause to believe that Respondent committed the crimes and bound the charges over for proceedings in the district court. A trial court is required to hold a preliminary hearing if there has been no grand jury indictment or preliminary hearing prior to the entry of a plea of not guilty by reason of insanity (NGRI). At arraignment, Respondent's attorney sought to enter a plea of NGRI over Respondent's objection. A doctor at the Colorado Mental Health Institute opined that Respondent was then legally incompetent. After Respondent was restored to competency, the prosecution stated that it would stipulate to the plea of NGRI, thereby agreeing that Respondent was insane on the date of the commission of the offense. Respondent's counsel again asked the court to accept the NGRI plea over Respondent's objection. The court asked Respondent if he had anything he'd like to say, and he responded "I think [my attorney] summed it up for me but I'm hoping to prove that I didn't do this in trial." Based on the prosecution's stipulation and the mental health evaluations before it, the district court accepted the NGRI plea and then found Respondent NGRI. The court then committed Respondent to the Department of Human Services. Respondent appealed, and the court of appeals held that Respondent was deprived of his right to a jury trial. The court of appeals held that Respondent had both a statutory and a constitutional right to a jury trial on the merits and his affirmative defense of insanity. After its review of the appellate court's decision, the Supreme Court held that when a defendant has entered a plea of not guilty by reason of insanity and the prosecution concedes that the defendant was insane at the time of the commission of the offense, the defendant has neither a statutory nor a constitutional right to a jury trial on the affirmative defense of insanity or the merits of the charged offense. Accordingly, the supreme court reversed the appellate court and remanded the case for further proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.