In Re The People of the State of Colorado v. Adetayo Sotade.

2025 CO 38
CourtSupreme Court of Colorado
DecidedJune 9, 2025
Docket25SA9
StatusPublished

This text of 2025 CO 38 (In Re The People of the State of Colorado v. Adetayo Sotade.) is published on Counsel Stack Legal Research, covering Supreme Court of Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re The People of the State of Colorado v. Adetayo Sotade., 2025 CO 38 (Colo. 2025).

Opinion

2025 CO 38

In Re The People of the State of Colorado, Plaintiff
v.
Adetayo Sotade. Defendant

No. 25SA9

Supreme Court of Colorado, En Banc

June 9, 2025


          Original Proceeding Pursuant to C.A.R. 21 Douglas County District Court Case No. 21CR60 Honorable Victoria Klingensmith, Judge

          ORDER MADE ABSOLUTE

          Attorneys for Plaintiff: Philip J. Weiser, Attorney General Kelley M. Dziedzic, Assistant Attorney General Denver, Colorado

          Attorneys for Defendant: Megan A. Ring, Public Defender Michael C. Mattis, Deputy Public Defender Denver, Colorado

          Ara Ohanian, Deputy Public Defender Elizabeth Orton, Deputy Public Defender Castle Rock Colorado

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          Attorneys for Respondent Douglas County District Court: Philip J. Weiser, Attorney General Lauren M. Dickey, First Assistant Attorney General Brady J. Grassmeyer, Senior Assistant Attorney General Conor A. Kruger, Assistant Attorney General Denver, Colorado

          Attorneys for Amicus Curiae Office of the Alternate Defense Counsel: Gibson, Dunn & Crutcher LLP John Partridge Al Kelly NoahLani Litwinsella Denver, Colorado

          JUSTICE HART delivered the Opinion of the Court, in which CHIEF JUSTICE MÁRQUEZ, JUSTICE BOATRIGHT, JUSTICE HOOD, JUSTICE GABRIEL, JUSTICE SAMOUR, and JUSTICE BERKENKOTTER joined.

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          OPINION

          HART JUSTICE

         ¶1 In this original proceeding, we consider whether a show-cause hearing under section 24-72-305(7), C.R.S. (2024) ("subsection 305(7)"), of the Colorado Criminal Justice Records Act ("CCJRA"), can be held in a district court outside of the district where the requested records are located. The question presents itself here because the Colorado Bureau of Investigations ("CBI") is located in Jefferson County, where it maintains its records, and some of those records are being sought in a criminal case in Douglas County District Court.

         ¶2 Subsection 305(7) provides that a party who is denied access to inspect a record covered by the CCJRA may submit an application "to the district court of the district wherein the record is found for an order directing the custodian of such record to show cause why said custodian should not permit the inspection of such record." The parties' dispute here turns on two questions: (1) whether the word "may," as used in the subsection, is mandatory or permissive; and (2) whether the Douglas County District Court has ancillary jurisdiction over a CCJRA application, independent of the statutory provision.

         ¶3 We conclude that the plain language of the statute requires that a CCJRA show-cause hearing take place in the district court of the district where the records are found, and that ancillary jurisdiction is unavailable because the statutory

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provision squarely applies. Accordingly, we make the order to show cause absolute.

         I. Facts and Procedural History

         ¶4 Adetayo Sotade is a defendant in an ongoing criminal case in Douglas

         County, where he is represented by counsel from the Office of the State Public Defender ("OSPD"). He is charged with second degree kidnapping, sexual assault, and unlawful sexual contact. As part of the underlying criminal investigation, the CBI conducted forensic laboratory testing. During the pendency of Sotade's criminal case, however, the CBI learned that one of its DNA analysts, Yvonne "Missy" Woods, had tampered with DNA testing in numerous cases over the course of decades. Though another CBI analyst conducted the testing in Sotade's case, Woods was the technical reviewer.

         ¶5 Sotade endorsed Woods as a witness and, in April 2024, issued two Subpoenas Duces Tecum ("SDTs") to the CBI for its internal affairs investigation records related to Woods, as well as other lab records relating to the primary analyst in his case. The CBI produced responsive documents, which the district court reviewed and provided to the parties subject to a protective order.

         ¶6 In July and September 2024, the OSPD submitted two records requests to the CBI, pursuant to the CCJRA, seeking records related to (1) "any and all" cases in which Woods was the analyst or technical reviewer and (2) "all" of the cases in

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which Woods had testified in a courtroom since 2007. The CBI's custodian of records responded to both CCJRA requests, (1) explaining that the custodian had made the discretionary choice to withhold the records of cases in which Woods was an analyst or technical reviewer; and (2) providing a list of jurisdictions and dates where Woods had given courtroom testimony during the requested timeframes, but with the case names and numbers redacted.

         ¶7 Sotade subsequently filed an Application to Show Cause ("the Application") in his criminal case, contesting the CBI's denial of the OSPD's records request. Within days, the CBI responded by filing a Motion to Quash or Dismiss Public Defender's Application to Show Cause for Lack of Jurisdiction. It argued that the Douglas County District Court lacked jurisdiction over the Application because the records at issue were located at the CBI's headquarters in Jefferson County.

         ¶8 The district court held a hearing on the Application to determine whether it could exercise jurisdiction under subsection 305(7) or ancillary jurisdiction under Woo v. El Paso County Sheriff's Office, 2022 CO 56, 528 P.3d 899. The court concluded that it could exercise ancillary jurisdiction over the Application and scheduled a show-cause hearing.

         ¶9 The CBI thereafter filed a Petition for Rule to Show Cause in this court, pursuant to C.A.R. 21, arguing that the district court lacked jurisdiction over the

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application because (1) the CCJRA requires anyone who is denied access to inspect a criminal justice record to submit an application in the district court of the district where the records are located, and (2) ancillary jurisdiction is unavailable under the circumstances presented here. We granted the CBI's petition.[1]

         II. Analysis

         ¶10 We begin by explaining why exercising our original jurisdiction under C.A.R. 21 is appropriate. Then, we address the core tenets of statutory interpretation and conclude that the plain language of subsection 305(7) requires a person whose records request was denied to seek a CCJRA show-cause hearing in the district court of the district where the records are found. We then discuss the doctrine of ancillary jurisdiction and hold that it is inapplicable here because subsection 305(7) applies. We therefore make the order to show cause absolute.

         A. Our C.A.R. 21 Jurisdiction

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Bluebook (online)
2025 CO 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-people-of-the-state-of-colorado-v-adetayo-sotade-colo-2025.