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In re People v. Sprinkle.

2021 CO 60. No. 21SA3. Open Records—Subject Matter Jurisdiction—Statutory Interpretation—Original Jurisdiction.

June 28, 2021

In this original proceeding, the Supreme Court reviewed the district court’s order requiring the El Paso County Sheriff’s Office to give petitioner, who is the defendant in the underlying criminal action, access to internal investigation files about two of its deputies.

The Supreme Court concluded that the district court properly exercised its subject matter jurisdiction in resolving this controversy through a hearing to show cause, as provided under the Colorado Criminal Justice Records Act (CCJRA), CRS § 24-72-303, and correctly interpreted the CCJRA as requiring release of the records. The Court held that a records custodian for a criminal justice agency may not deny a request to inspect internal investigation files under CRS § 24-72-303(4)(a) simply because the requester has not referenced a “specific, identifiable incident” of alleged misconduct in the request.

Accordingly, the Court discharged the rule.

Official Colorado Supreme Court proceedings can be found at the Colorado Supreme Court website.

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