In re People v. Clark.

2026 CO 67. No. 26SA165. Forensic Science Integrity Act—Crim. P. 17—Spykstra Test—Discovery.

October 19, 2026

In this original proceeding, the supreme court considered the legality of a wide-ranging subpoena served on the Colorado Bureau of Investigation (CBI) by a defendant awaiting retrial on criminal charges. In that subpoena, Clark requested information about cases other than his own on which former CBI DNA analyst Woods worked. The court concluded that the subpoena exceeded the bounds of Crim. P. 17 and that Clark failed to satisfy the five-factor test required by People v. Spykstra, 234 P.3d 662, 669 (Colo. 2010). The court also held that the Colorado Forensic Science Integrity Act, CRS §§ 16-12-301 to -312, doesn’t authorize a defendant to subpoena discovery from CBI without first adhering to the act’s procedural requirements. Therefore, the court concluded that the district court erred by denying CBI’s motion to quash the subpoena and remanded the case to the district court for further proceedings.