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. …