People in Interest of A.T.S.

2025 COA 53
CourtColorado Court of Appeals
DecidedMay 29, 2025
Docket22CA1175
StatusPublished

This text of 2025 COA 53 (People in Interest of A.T.S.) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People in Interest of A.T.S., 2025 COA 53 (Colo. Ct. App. 2025).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY May 29, 2025

2025COA53

No. 22CA1175, People in Interest of A.T.S. — Constitutional Law — Sixth Amendment — Confrontation Clause; Trials — Use of Closed-Circuit Television — Presence of the Defendant

A division of the court of appeals addresses when a child

witness may testify via closed-circuit television in a criminal case.

The division holds that a child witness may testify by closed-circuit

television only if the trial court finds, among other factors, that the

child would suffer serious emotional distress or be traumatized by

the presence of the defendant in the courtroom. See Maryland v.

Craig, 497 U.S. 836, 856 (1990). While the child may have various

fears about testifying, the presence of the defendant must be “the

dominant reason” preventing the child from testifying in open court.

United States v. Bordeaux, 400 F.3d 548, 555 (8th Cir. 2005).

In this case, the juvenile court found that the presence of the

defendant’s parents, not the defendant himself, was the dominant reason that the child victim could not testify in open court. Thus,

the division concludes that the court erred by permitting the victim

to testify via closed-circuit television. Nevertheless, after reviewing

the record, the division determines that this error was

constitutionally harmless.

Because the division also rejects the defendant’s other

contentions regarding prosecutorial misconduct and sufficiency of

the evidence, it affirms the juvenile court’s judgment. COLORADO COURT OF APPEALS 2025COA53

Court of Appeals No. 22CA1175 City and County of Denver Juvenile Court No. 21JD94 Honorable Laurie A. Clark, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of A.T.S.,

Juvenile-Appellant.

JUDGMENT AFFIRMED

Division I Opinion by JUDGE YUN J. Jones and Brown, JJ., concur

Announced May 29, 2025

Philip J. Weiser, Attorney General, Jacob R. Lofgren, Senior Assistant Attorney General, Gina M. Nykerk, Assistant Attorney General Fellow, Denver, Colorado, for Petitioner-Appellee

Megan A. Ring, Colorado State Public Defender, Mark Evans, Deputy State Public Defender, Denver, Colorado, for Juvenile-Appellant ¶1 A.T.S. appeals his adjudication for sexual assault on a child.

He contends that (1) the juvenile court reversibly erred by allowing

the victim to testify by closed-circuit television; (2) the prosecutor

engaged in misconduct during closing argument; and (3) there was

insufficient evidence that an act occurred after A.T.S. turned ten

years old. We reject these arguments and affirm the judgment.

¶2 In addressing A.T.S.’s contentions, we confront a novel issue

in Colorado: Can a juvenile court permit a child witness to testify

via closed-circuit television primarily because the child would be

traumatized by the presence of the defendant’s family? We hold

that it cannot. A child witness may testify by closed-circuit

television only if the trial court finds, among other factors, that the

child would be traumatized by the presence of the defendant in the

courtroom. Maryland v. Craig, 497 U.S. 836, 856 (1990). While the

child may have various fears about testifying, the presence of the

defendant must be “the dominant reason” preventing the child from

testifying in open court. United States v. Bordeaux, 400 F.3d 548,

555 (8th Cir. 2005).

¶3 Because the juvenile court found that A.T.S.’s presence was

not the dominant reason that the victim could not testify in open

1 court, we conclude that it erred by permitting the victim to testify

via closed-circuit television. However, after reviewing the record, we

determine that this error was constitutionally harmless.

I. Background

¶4 When the victim was nine years old, he disclosed to his mother

that A.T.S., his older cousin on the paternal side of the family, had

sexually molested him. In a forensic interview, the victim described

anal-genital, oral-genital, and manual-genital contact that occurred

when he was between the ages of four and seven and A.T.S. was

between the ages of ten and thirteen. The victim said that A.T.S.

had told him the abuse would make him stronger but that, when he

was five or six, he “noticed [he] wasn’t getting strong” and told

A.T.S. to stop. He said he told his mother because he had been

“hiding it for four or five years” and did not “want it [to be] a secret”

any longer.

¶5 The People filed a petition in delinquency charging A.T.S. with

one count of sexual assault on a child. A jury found him guilty as

charged, and the juvenile court sentenced him to two years of

probation.

2 II. Testimony By Closed-Circuit Television

¶6 A.T.S. contends that the juvenile court violated his

confrontation rights by permitting the victim to testify by closed-

circuit television. We agree that the court erred, but we conclude

that the error was harmless beyond a reasonable doubt.

A. Additional Background

¶7 Before trial, the People moved to allow the victim to testify by

closed-circuit television, explaining that the victim’s mother had

“indicated that testifying in front of his cousin and his cousin’s

parents, namely his aunt and uncle, could cause [the victim] to

suffer serious emotional distress.” A.T.S. objected. In support of

their motion, the People submitted an affidavit from the victim’s

therapist, who said that she had become

very familiar with the dynamics of [the victim’s] paternal family, including relationships with aunts, uncles, cousins, and grandparents. In working with [the victim], it is my observation that [the victim] struggled with the power and control dynamics present in his relationships with those family members. I further observed that, due to those power and control dynamics, [the victim] struggled to advocate for himself with that side of the family.

3 Accordingly, she expressed her “clinical opinion . . . that [the

victim’s] testifying in a courtroom directly in front of his paternal

cousin, aunt, and uncle would cause [the victim] to experience

trauma, and that that trauma is very likely to inhibit [the victim’s]

ability to communicate in court.”

¶8 After a hearing, the court found that, “based on the forensic

interview that I’ve seen, the child hearsay hearing that I had, and

the statements in the [therapist’s] affidavit, I am much less worried

about . . . the [victim] being in the same room with [A.T.S.] than I

am with the influence of [A.T.S.’s] parents and their relationship to

the [victim].” It then determined “that testimony by the [victim] in

the courtroom in the presence of [A.T.S.], and [A.T.S.’s] parents, . . .

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Related

Mattox v. United States
156 U.S. 237 (Supreme Court, 1895)
Maryland v. Craig
497 U.S. 836 (Supreme Court, 1990)
Larry Glen Hoversten v. State of Iowa
998 F.2d 614 (Eighth Circuit, 1993)
United States v. Edward E. Bordeaux, Jr.
400 F.3d 548 (Eighth Circuit, 2005)
People v. Avila
944 P.2d 673 (Colorado Court of Appeals, 1997)
Mills v. State
535 S.E.2d 1 (Court of Appeals of Georgia, 2000)
People v. Mason
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Rodriguez v. People
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Wend v. People
235 P.3d 1089 (Supreme Court of Colorado, 2010)
People v. Strock
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People v. Fry
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Arteaga-Lansaw v. People
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People v. Lopez
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People v. Argomaniz-Ramirez
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Domingo-Gomez v. People
125 P.3d 1043 (Supreme Court of Colorado, 2005)
People v. Rodriguez
209 P.3d 1151 (Colorado Court of Appeals, 2009)

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2025 COA 53, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-in-interest-of-ats-coloctapp-2025.