People v. Zachary Orion Roper

547 P.3d 1154, 2024 COA 9
Colorado Court of Appeals·Decided January 25, 2024·No. 21CA0309·Published·Cited by 2 cases

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 January 25, 2024

2024COA9

No. 21CA0309, People v. Roper — Constitutional Law — Sixth Amendment — Right to Public Trial — Partial Courtroom Closure — Waller Test — Findings

A division of the court of appeals resolves an open issue,

concluding that when a trial court’s findings under Waller v.

Georgia, 467 U.S. 39 (1984), are not sufficient to support a partial

courtroom closure, but a remand for further findings does not

appear to be futile, a limited remand is an appropriate remedy. COLORADO COURT OF APPEALS 2024COA9

Court of Appeals No. 21CA0309 Boulder County District Court No. 19CR447 Honorable Thomas F. Mulvahill, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Zachary Orion Roper,

Defendant-Appellant.

ORDER OF LIMITED REMAND

Division VII Opinion by JUDGE TOW Brown and Schock, JJ., concur

Announced January 25, 2024

Philip J. Weiser, Attorney General, Jessica E. Ross, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Taylor J. Hoy, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 The COVID-19 pandemic had far-reaching effects on every

aspect of life, and the criminal justice system was certainly no

exception. Courts had to grapple with the difficult question of how

to conduct a jury trial in a manner that simultaneously protected

the defendant’s rights to a speedy and fair trial, while safeguarding

the health of the participants and the public. In particular, the

virus necessitated certain social distancing requirements, making

the task of providing a public trial even more challenging.

¶2 One common method adopted by courts was to provide an

audio and video livestream of the proceedings to the public. In

many cases, this included permitting the public to view the

proceedings while sitting, socially distanced, in a different

courtroom in the courthouse.

¶3 The trial court invoked this procedure when defendant,

Zachary Orion Roper, was tried for and convicted of sexual

assault (victim helpless) and sexual assault (victim incapable of

appraising the nature of their conduct). On appeal of his

conviction, Roper contends, among other things, that this

arrangement was a partial courtroom closure that was not

supported by sufficient findings. See Waller v. Georgia, 467 U.S.

1 39, 48 (1984) (holding that a trial court “must make findings

adequate to support the closure”). He further contends that the

failure to make adequate findings to justify the partial courtroom

closure constitutes structural error requiring automatic reversal of

his convictions.

¶4 Roper’s challenge requires us to resolve a question that has

often been mentioned but never conclusively resolved by a Colorado

appellate court: Does the trial court’s failure to make sufficient

findings at the time of the court closure amount to structural error

or can that insufficiency be remedied by remanding to the trial

court for further findings? We conclude that, where the trial court’s

findings are incomplete, but it appears that a remand would not be

futile, an appellate court is not precluded from remanding to the

trial court for more findings. We further conclude that such a

remand is appropriate here.

I. Background

¶5 Roper’s trial was originally scheduled for April 2020, but he

requested a continuance due to the COVID-19 pandemic. The

People agreed, and the case was continued. After a second

continuance, Roper’s trial was rescheduled for October 2020.

2 Roper asked for a third continuance because of the pandemic,

stating that he would waive his speedy trial right. Roper also

requested that four family members and four friends be permitted

to attend his trial in person. He asserted that not allowing these

people to be present in the courtroom during his trial would violate

his right to a public trial.

¶6 At the pretrial hearing, the trial court denied Roper’s request

for a third continuance. The trial court and parties then discussed

the modified trial procedures in place as a result of the pandemic.

The trial court noted that these procedures were “formulated with

the input of the district attorney, the office of the public defender,

probation, [and] security, and [were] ultimately vetted and approved

by Boulder County Public Health.”

¶7 The trial court also mentioned Waller and stated that “[w]e are

not going to be able to accommodate family members or friends in

the actual courtroom during the trial.” Instead, the trial court

advised the parties that, due to current COVID-19 health and safety

regulations, jury selection would be done in one of two essentially

identical courtrooms that could hold twenty-two potential jurors

with appropriate social distancing, and the jury assembly room

3 could hold twenty-eight additional potential jurors who would

observe the jury selection via Webex. The court informed the

parties that the trial would be in a smaller courtroom, and that the

public could observe the trial proceedings via Webex, either online

or from the public viewing area located in another courtroom in the

courthouse. The court said that during the trial, the twelve jurors

would be seated in the gallery bench seats. The court also agreed

— at Roper’s request — to advise each witness that the trial was

being observed via Webex.1

¶8 Both during the pretrial hearing and at the start of trial, Roper

objected to restricting the public’s access to the courtroom. In

response to the latter objection, the trial court said, “With respect to

your position about the public in the courtroom, the court facilities

aren’t sufficiently large to allow the public to be in the physical

courtroom where the trial is taking place. So public access to the

courtroom is being provided through Webex.” The court also stated

1 The trial court denied Roper’s request to notify the jury that his

friends and family were watching the trial and to have a screen in the courtroom showing the participants who were watching. The court also denied Roper’s suggestion to display pictures of his family and supporters in the courtroom as a way of informing the jurors and witnesses of their presence on the livestream.

4 that Roper’s family could watch the livestream in the adjacent

courtroom and could have contact with Roper during breaks.

¶9 After the trial, in a written and signed minute order describing

the trial proceedings, the trial court noted that the trial

“proceedings were held pursuant to the health and safety provisions

of the 20th Judicial District Court’s Administrative Order 20-110 –

Resumption of Jury Trials.” The trial court also noted the

applicability of “the 20th Judicial District Court’s Plan for Resuming

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People v. Zachary Orion Roper, 547 P.3d 1154, 2024 COA 9 (Colo. Ct. App. 2024).

547 P.3d 1154 (People v. Zachary Orion Roper) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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