People v. Fidel Castro

CourtColorado Court of Appeals
DecidedSeptember 8, 2022
Docket18CA1878
StatusPublished

This text of People v. Fidel Castro (People v. Fidel Castro) 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 v. Fidel Castro, (Colo. Ct. App. 2022).

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 September 8, 2022

2022COA101

No. 18CA1878, People v. Castro — Constitutional Law — Due Process — Fourth Amendment — Searches and Seizures — Custodial Interrogation — Miranda — Post-advisement Silence — Fifth Amendment — Right to Remain Silent

In this case, following his arrest and receipt of Miranda

warnings, the defendant twice made very brief, exculpatory

statements to the police. At trial, the defendant testified to various

details consistent with those statements. The prosecutor cross-

examined the defendant about, and later commented in closing

argument on, why he had not given the police those details

following, or since, his arrest.

A division of the court of appeals considers whether Doyle v.

Ohio, 426 U.S. 610 (1976), and its progeny, prohibited the

prosecutor from cross-examining the defendant about, and

commenting in closing argument on, his failure to inform the authorities of the details to which he testified at trial. Because the

division concludes that it did, the division reverses and remands for

a new trial. COLORADO COURT OF APPEALS 2022COA101

Court of Appeals No. 18CA1878 Morgan County District Court No. 17CR1 Honorable Carl S. McGuire III, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Fidel Castro,

Defendant-Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division I Opinion by JUDGE DAILEY Berger and Tow, JJ., concur

Announced September 8, 2022

Philip J. Weiser, Attorney General, John T. Lee, First Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Lynn Noesner, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 An individual who has been arrested and advised of his or her

Miranda rights1 will sometimes say something to the police and

then testify somewhat differently at trial. In that situation, a

prosecutor will often want to ask about, and comment in closing

argument on, why the accused did not tell the police what he told

the jury. In some circumstances, though, the prosecutor’s

questions and comments will impermissibly penalize the accused

for not saying something after having been advised that he doesn’t

have to say anything. And because that was the case here, we

reverse the conviction of defendant, Fidel Castro, for sexual assault

and remand for a new trial.

I. Background

¶2 Castro and C.V., the victim, knew each other through two

other people who were a couple. The couple hosted a small New

Year’s Eve gathering in Brush, Colorado.2 Before that evening,

Castro and C.V. had been on at least one date together. At

midnight, they kissed.

1 Miranda v. Arizona, 384 U.S. 436 (1966).

2 Castro, C.V., and C.V.’s three minor children were the only guests in attendance.

1 ¶3 The host couple went to bed, leaving Castro, C.V., and C.V.’s

then-sleeping children in the living room. According to C.V., the

following then happened:

• Around 3 a.m., as she was heading to a couch to go to

sleep, Castro approached and kissed her, and put his

hands down the front of her pants.

• Castro then repeatedly kissed her, bit her genitals and

thighs, and digitally penetrated her, at first with his

fingers, and then with his whole hand.

• Although she told Castro to stop and that he was being

“too rough,” he did not stop, replying, instead, “Too

rough? Or not rough enough?”

¶4 The encounter ended when one of C.V.’s children woke up and

asked for a drink of water. Afterward, Castro asked C.V. for her

phone number. When she could not find a pen and paper in the

kitchen to write it down, C.V. told Castro to find her on Facebook

Messenger. Castro left shortly thereafter.

¶5 Around 9 p.m. that evening, C.V. went to the emergency room,

where she was treated for bruising and lacerations on her genitals,

2 bite marks on her neck and genitals, and damage to her urethra. A

DNA test showed the presence of Castro’s saliva on those areas.

¶6 Castro was arrested the next day. During the arrest, a police

officer advised him of his Miranda rights. Castro declined to speak

with the officer. Subsequently, while being transported to jail,

Castro volunteered, very briefly, that the encounter with C.V. “was

consensual.” The following day, during a buccal swab collection,

Castro spontaneously told the swabbing officer the very same thing.

¶7 Castro’s theory of defense was that he and C.V. had previously

been sexually involved during a romantic relationship, and the

encounter that night had been consensual.

¶8 Nevertheless, the jury convicted Castro of sexual assault, and

the trial court sentenced him under the Colorado Sex Offender

Lifetime Supervision Act of 1998 (SOLSA), §§ 18-1.3-1001 to -1012,

C.R.S. 2021, to an indeterminate term of twenty-five years to life

imprisonment in the custody of the Department of Corrections.

¶9 Castro now appeals, contending that (1) reversal is required

because the prosecutor’s use of his post-advisement silence violated

his due process rights and (2) SOLSA is unconstitutional.

3 ¶ 10 Because we agree with Castro’s first contention, we do not

address his second one.

II. Evidence and Comments on Castro’s Post-Arrest Silence

¶ 11 Castro contends that the trial court reversibly erred when it

permitted the prosecutor to cross-examine him about, and

comment in closing argument on, his post-arrest silence. We agree.

A. Facts

¶ 12 Castro declined to speak with law enforcement after being

arrested and advised of his Miranda rights, but he later volunteered

to two officers that the sexual encounter with C.V. had been

consensual.

¶ 13 At trial, Castro testified that (1) he and C.V. had a prior

relationship; (2) C.V. initiated sexual contact earlier that evening by

putting her hands down his pants while kissing him; (3) he believed

she was inviting him to join her on the couch when he began

kissing her; (4) she never told him to stop during the encounter; (5)

he thought she was enjoying herself during the encounter; (6) he

was unaware, until the next day, that he had hurt her; and (7) he

thought the entire encounter was consensual.

4 ¶ 14 On cross-examination, the prosecutor inquired of him as

follows:

PROSECUTOR: Did you tell that deputy . . . everything you just told us here this morning?

CASTRO: No, I did not.

PROSECUTOR: Why not?

¶ 15 Before Castro could answer, defense counsel objected, arguing

that this line of questioning suggested that Castro was given the

opportunity to give his account and chose not to, and that it

“basically [sought] to punish Mr. Castro for exercising his right to

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Chapman v. California
386 U.S. 18 (Supreme Court, 1967)
United States v. Hale
422 U.S. 171 (Supreme Court, 1975)
Doyle v. Ohio
426 U.S. 610 (Supreme Court, 1976)
Anderson v. Charles
447 U.S. 404 (Supreme Court, 1980)
United States v. Joseph Goldman
563 F.2d 501 (First Circuit, 1977)
United States v. Casamento
887 F.2d 1141 (Second Circuit, 1989)
United States v. Richard Lee Canterbury
985 F.2d 483 (Tenth Circuit, 1993)
United States v. Ramon Velarde-Gomez
269 F.3d 1023 (Ninth Circuit, 2001)
People v. Ortega
597 P.2d 1034 (Supreme Court of Colorado, 1979)
People v. Hardiway
874 P.2d 425 (Colorado Court of Appeals, 1993)
People v. Quintana
665 P.2d 605 (Supreme Court of Colorado, 1983)
United States v. Caruto
532 F.3d 822 (Ninth Circuit, 2008)
People v. Fry
92 P.3d 970 (Supreme Court of Colorado, 2004)
People v. Welsh
80 P.3d 296 (Supreme Court of Colorado, 2003)
People v. Welsh
58 P.3d 1065 (Colorado Court of Appeals, 2002)
People v. Orozco
210 P.3d 472 (Colorado Court of Appeals, 2009)
People v. Rogers
68 P.3d 486 (Colorado Court of Appeals, 2002)
United States v. Jose Ramirez-Estrada
749 F.3d 1129 (Ninth Circuit, 2014)

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People v. Fidel Castro, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-fidel-castro-coloctapp-2022.