The People of the State of Colorado v. Donald Louis Gerle.

CourtSupreme Court of Colorado
DecidedJune 23, 2026
Docket24SC542
StatusPublished

This text of The People of the State of Colorado v. Donald Louis Gerle. (The People of the State of Colorado v. Donald Louis Gerle.) 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
The People of the State of Colorado v. Donald Louis Gerle., (Colo. 2026).

Opinion

2026 CO 53

The People of the State of Colorado, Petitioner
v.
Donald Louis Gerle. Respondent

No. 24SC542

Supreme Court of Colorado, En Banc

June 23, 2026


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          Certiorari to the Colorado Court of Appeals Court of Appeals Case No. 23CA481

          Attorneys for Petitioner: Philip J. Weiser, Attorney General Jaycey DeHoyos, Assistant Attorney General Denver, Colorado

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          Attorneys for Respondent: Fuller &Ahern, P.C. Brian M. Close Parker, Colorado

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

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          OPINION

          BERKENKOTTER, JUSTICE.

         ¶1 Donald Louis Gerle was charged with first and second degree assault and false imprisonment. See § 18-3-202(1)(a), C.R.S. (2025); § 18-3-203(1)(g), C.R.S. (2025); § 18-3-303(1), C.R.S. (2025). The People alleged that he repeatedly beat the victim, his wife, between November 12, 2021, and November 15, 2021; confined her in a closet during the last fourteen hours of the assaults; and caused her to suffer serious bodily injury and other significant injuries, including two black eyes, two broken ribs, plate-sized bruises on her body, and a collapsed lung.

         ¶2 At trial, Gerle sought to introduce texts that he and the victim had exchanged on November 8, three days before the charged incident began. The texts reflected that the two had previously engaged in sexual bondage, discipline, dominance, submission, sadism, and masochism ("BDSM") role-playing. Gerle claimed that the texts were probative of the consent element of his false imprisonment charge as well as the intent element of all three charges. The People objected, arguing that the texts should be excluded under Colorado's rape shield statute, § 18-3-407, C.R.S. (2025), and under CRE 401, 402, and 403.

         ¶3 The trial court sustained the objection, ruling that discussion of sexual BDSM-related evidence violated the rape shield statute and that the texts were not relevant because they did not relate to the time during which the charged conduct occurred. The court accordingly barred defense counsel from mentioning BDSM

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in their opening statement, limited counsel's questioning of the victim regarding the text messages, and declined to admit the texts as evidence.

         ¶4 Gerle was convicted at trial and appealed, arguing that the trial court erroneously (1) applied the rape shield statute, (2) denied his request for a mistrial, and (3) excluded evidence during his cross-examination of the victim—which cumulatively warranted reversal.

         ¶5 A division of the court of appeals concluded that the trial court erred in applying the rape shield statute because Gerle had not been charged with sexual assault. People v. Gerle, No. 23CA481, ¶¶ 22, 25 (July 11, 2024). It then determined that the trial court erred in excluding the BDSM-related evidence because the texts showed the "particular nature" of Gerle and the victim's relationship and thus were relevant to consent and lack of intent. Id. at ¶ 38 (quoting People v. Garcia, 179 P.3d 250, 258 (Colo.App. 2007)). The division reversed and remanded the case for a new trial. Id. at ¶ 47.

         ¶6 We now reverse the division's judgment. We conclude that the trial court did not abuse its discretion in excluding the BDSM-related evidence as irrelevant. See CRE 401. While a prior act may be relevant to charged conduct, the prior act here involved a BDSM encounter that was explicitly sexual in nature. No evidence indicated that Gerle and the victim planned or were otherwise engaged in a consensual sexual BDSM encounter during the charged incident. Therefore, this

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evidence was inadmissible to suggest that the victim consented to Gerle confining her or to suggest that Gerle did not intend to confine the victim against her will or to assault her, but rather acted recklessly.[1] That is, the text messages do not make it more probable that the victim consented to being confined or less probable that Gerle intended to confine and assault the victim.

         ¶7 We need not address the division's decision as to the rape shield statute because the People concede the trial court's error.

         I. Facts and Procedural History

         ¶8 Gerle and the victim began arguing on Thursday, November 11, 2021, when the victim, in response to a question from Gerle, said she could not remember the name of her ex-boyfriend. Gerle did not believe the victim, and what began as a verbal argument escalated into physical abuse, which intensified over the course of the next three days. On Thursday, Gerle broke the victim's laptop and printer. On Friday, when the argument about the ex-boyfriend resumed, Gerle used a camera tripod like a bat and hit the victim with it until the tripod's legs bent.

         ¶9 After the argument resumed on Saturday evening, Gerle confined the victim to a walk-in closet for roughly fourteen hours (into the early morning hours on

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Sunday) and beat her with his hands and various objects including hangers, a belt buckle, and steel-toe boots. Gerle insisted, while he had the victim confined, that she write down the name of her ex-boyfriend. While in the closet, the victim lost consciousness.

         ¶10 When the victim regained consciousness and was eventually able to get up, she drove herself to the hospital. There, she was treated for two black eyes, a collapsed lung, a puncture wound on her ankle, two broken ribs, and bruises all over her body, including behind her ears. Gerle was charged with assault in the first degree, assault in the second degree, and false imprisonment.

         ¶11 At trial, Gerle's opening statement suggested that the charged conduct was part of Gerle and the victim's "ongoing and regular sexual fantasy role-playing." The People objected, noting that the defense had not provided notice of their intent to offer evidence of the victim's past sexual conduct, as required under the rape shield statute. See § 18-3-407(2)(a). The trial court sustained the objection under the rape shield statute and barred defense counsel from mentioning the sexual BDSM role-playing during opening statement.

         ¶12 Gerle later sought to admit texts that he and the victim exchanged on November 8. He argued that they were relevant to disprove the consent element of the false imprisonment charge, and the intent element of all the charges. The texts included a screenshot of an erotic novel the victim had read, Gerle's and the

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victim's discussion of the novel, and descriptions of a variety of their sexual fantasies.

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Related

People v. Botham
629 P.2d 589 (Supreme Court of Colorado, 1981)
People v. MacLeod
176 P.3d 75 (Supreme Court of Colorado, 2008)
People v. Garcia
179 P.3d 250 (Colorado Court of Appeals, 2008)
Fletcher v. People
179 P.3d 969 (Supreme Court of Colorado, 2007)
In Re People v. Elmarr
2015 CO 53 (Supreme Court of Colorado, 2015)
v. Kent
2020 CO 85 (Supreme Court of Colorado, 2020)
People v. Clark
2015 COA 44 (Colorado Court of Appeals, 2015)
People v. Dunham
2016 COA 73 (Colorado Court of Appeals, 2016)

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The People of the State of Colorado v. Donald Louis Gerle., Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-people-of-the-state-of-colorado-v-donald-louis-gerle-colo-2026.