Archuleta v. Colorado
Annotate this CaseDefendant-respondent Sandra Archuleta took care of her four-month-old grandson, D.A., for one week. Several hours after D.A.’s mother picked him up, she returned to Archuleta’s home with D.A. Archuleta noticed that D.A. did not appear to be breathing, so she attempted CPR and called 911. First responders arrived shortly thereafter and transported D.A. to the hospital, but he died the following morning. An autopsy revealed that D.A. had been suffering from dehydration and a bacterial infection that had started as pneumonia and that had spread to his blood. The prosecution subsequently charged Archuleta with one count of “child abuse resulting in death,” alleging that she caused D.A.’s death over the course of the week in which she took care of him. The issue this case presented for the Colorado Supreme Court's review centered on when a trial court must give a jury a so-called "modified unanimity instruction." Specifically, the issue reduced to whether defendant was entitled to such an instruction requiring that the 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 Supreme Court found that 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. And because, in light of the prosecution’s theory, the Court found no reasonable likelihood that the jurors disagreed on which specific act caused the child’s death, the Court concluded Archuleta was not entitled to a modified unanimity instruction here.
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