CLE Programs

The Office of the Federal Public Defender, in conjunction with the Colorado CJA Standing Committee, sponsors approximately 16 Continuing Legal Education Programs a year, accredited by the Colorado Supreme Court and the Wyoming State Bar.

For more information, contact Virginia Grady using the form below:

Mathis v United States clarifies

-- Dateline: June 23, 2016

Mathis v United States clarifies (i.e., makes it crystal clear) the difference between the categorical and the modified categorical approach to analyzing a "violent felony."

Today, the Supreme Court issued an opinion in Mathis v. United States, which is another in a long line of cases that flesh out when a court must use the categorical vs. the modified categorical approach in determining whether a state crime can qualify as a predicate “violent felony” under the Armed Career Criminal Act.  …

SCOTUS Allows Search Following Unconstitutional Stop when in Connection to Outstanding Arrest Warrant

-- Dateline: June 20, 2016

On Monday, June 20, the Supreme Court, upheld in a 5-3 decision, a conviction stemming from evidence obtained following an unconstitutional investigatory stop. See Utah v. Strieff, 2016 WL 3369419 (2016). The Court reasoned, under the so-called attenuation doctrine, that because the stop eventually lead to the legal execution of an arrest warrant, the evidence obtained therefrom was admissible at trial. …

10th Circuit Grants Habeas Relief for Brady Violation

In McCormick v. Parker (E. D. Okla.)(14-7095)(10-CV-00117-JHP-KEW), the 10th Circuit reversed the district court’s denial of petitioner’s writ of habeas corpus under 28 U.S.C. § 2254. The Court found that, under Brady v. Maryland, 373 U.S. 83 (1963), the state suppressed favorable and material evidence when it allowed a witness to testify falsely at trial. …

10th Circuit Says No to Compulsory Polygraph Testing

The Tenth Circuit made waves in United States v. Von Behren (D. Colo)(15-1033)(04-CR-0341-REB-1), when it invalidated the sexual history polygraph requirement of Mr. Von Behren’s state-approved sex offender treatment program. The program was a prerequisite of Mr. Von Behren’s terms of supervised release following a prison sentence. …