Colorado v. Lujan
Annotate this CaseAbel Lujan was charged with first-degree murder for the death of his girlfriend after she was found beaten and strangled behind a friend’s house. At trial, two women testified for the State about Lujan’s prior violent behavior towards them. Prior to admitting this evidence, the trial court read a limiting instruction, telling the jury that it could only consider the evidence for the purposes of establishing Lujan’s motive, intent, or common plan. A copy of this instruction was not given to the jury for deliberations; however, the jury did receive an instruction at the close of the evidence explaining that certain evidence could only be considered for the limited purposes for which it was admitted. While deliberating, the jury submitted a question seeking clarification about the limiting instruction. Over defense counsel’s objection, the trial court cleared the courtroom of the public and parties, leaving only the judge, bailiff, and court reporter; the judge then brought in the jury and reread the limiting instruction that it had previously read twice in open court. The jury ultimately found Lujan guilty of second-degree murder. Lujan appealed, arguing that the court’s actions when rereading the jury instruction constituted a courtroom closure that violated his Sixth Amendment right to a public trial. A division of the court of appeals agreed and reversed Lujan’s conviction. The State argued on certiorari review that the Colorado Supreme Court adopt a triviality standard, under which a defendant’s constitutional right to a public trial was not violated when the closure at issue was trivial. In so doing, the State argued that the brief courtroom closure here was trivial and therefore did not violate Lujan’s public trial right. The Court concurred with the State, adopted the standard and reversed the appellate court's decision.
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.