People v. Fields.
2025 COA 84. No. 20CA1708. Sentencing—Punishment for Habitual Criminals—Jury’s Role—Uniform Mandatory Disposition of Detainers Act—Jury Instructions—Victim Impact Evidence.
October 23, 2025
Fields was charged with kidnapping and sexually assaulting J.C. The charges stemmed from a 1994 crime that had gone unsolved for 22 years until detectives reprocessed DNA taken from J.C.’s vaginal swab and identified a match with Fields’s DNA. The prosecution filed the underlying charges against Fields on March 24, 2017. On May 7, 2017, while Fields was represented by a public defender, Fields’s wife sent a fax to the prosecutor and county court requesting final disposition of the charges under the Uniform Mandatory Disposition of Detainers Act (UMDDA) and seeking removal of the public defender. On May 19, the county court issued an order noting that it had received these motions, but stating that unless Fields’s wife was a licensed attorney, the motions were null. Fields himself filed a second UMDDA request, which was received on August 2, 2017. The trial court ultimately denied Fields’s request because the county court had nullified the May 7 request. Fields was convicted of kidnapping and sexual assault against J.C., and of five habitual criminal charges. Based on the habitual criminal charges, and because Fields had already been adjudicated a habitual criminal in a prior case, the court sentenced him to concurrent sentences of 96 years in prison for kidnapping and life in prison with the possibility of parole after 40 years for sexual assault. Fields’s convictions and sentences were previously affirmed, but that judgment was vacated and the case was remanded for further consideration in light of Erlinger v. United States, 602 U.S. 821 (2024).
On appeal, Fields argued that the trial court violated his statutory rights by adjudicating the habitual criminal counts, because for purposes of the habitual criminal statute, CRS § 18-1.3-803, Erlinger requires a jury finding on whether a defendant’s prior convictions were separately brought and tried and whether they arose out of separate and distinct criminal episodes. Here, when Fields committed the underlying offenses in 1994, CRS § 16-13-103 provided that a defendant was entitled to a jury trial on habitual criminal charges, but only on the issue of identity. The statute was later amended to allow a court to determine habitual criminal charges as a matter of law for all informations filed on or after July 1, 1995. Though Fields committed the underlying offenses in 1994, the prosecution filed its complaint and information in 2017, so no jury trial was required. But Fields nonetheless received a jury trial on the issue of identity, so his statutory rights were not violated.
Fields also argued that the trial court violated his constitutional rights under Erlinger and committed a structural error by adjudicating the habitual criminal counts. As to whether the alleged error is structural, the US Supreme Court has consistently held that most constitutional errors can be harmless. Washington v. Recuenco, 548 U.S. 212, 218 (2006). And the jury’s determination of whether prior convictions were separately brought and tried and arose out of separate and distinct criminal episodes can be established based on the judicial records introduced at the habitual criminal trial, so it may be reviewed for harmlessness. Erlinger error is thus not subject to automatic reversal for structural error. On the merits, Erlinger held that, under the Sixth Amendment, whether a criminal defendant’s prior convictions were committed on different occasions from one another for purposes of the Armed Career Criminal Act is a fact-laden inquiry that a jury must decide. The Colorado Supreme Court applied Erlinger in People v. Gregg, 2025 CO 57, and held that habitual criminal adjudications under § 18-1.3-803 must be determined by a jury. The trial court thus erred when it decided the habitual criminal counts. But here, the record contains charging documents for each of Fields’s offenses that show different dates, different locations, different victims, and different case numbers. This record thus supports the conclusion that any rational jury would have found, beyond a reasonable doubt, that Fields’s convictions were separately brought and tried and arose out of distinct criminal episodes. Accordingly, the error does not warrant reversal of Fields’s convictions.
Fields also contended that the trial court violated the UMDDA. He maintained that the court improperly relied on the law of the case doctrine because the county court abused its discretion by nullifying his May 7 UMDDA request. Fields did not appeal the timeliness of his trial as related to his August 2 UMDDA request. The UMDDA allows a prisoner to request final disposition of any untried indictment, information, or criminal complaint pending against them. Once the trial court and prosecution receive a UMDDA request, the prisoner must be brought to trial within 182 days. If a defendant invokes their rights but the trial court fails to comply with the 182-day deadline, the court loses jurisdiction, and the charges must be dismissed with prejudice. Here, Fields’s non-attorney wife was not authorized to file a UMDDA request, and Fields was not entitled to hybrid representation. Because the county court properly nullified the UMMDA request filed by Fields’s wife, the trial court properly concluded that this request was void.
Fields further asserted that the trial court reversibly erred by incorrectly instructing the jury on the elements of second degree kidnapping. The prosecution agreed that the instruction was incorrect but argued that reversal is not required. At the time of Fields’s trial, the law was settled that the definitional instruction given in his case was correct. Reviewing for plain error, the court of appeals determined that the error was obvious but not plain.
Fields also argued that he is entitled to a new trial based on improper admission of victim impact evidence. But even assuming that this testimony was improper, reversal is not required because the testimony was brief, was not referenced in closing argument, and was minor when compared with graphic evidence otherwise admitted at trial.
Lastly, Fields asserted that his life sentence for sexual assault is illegal because he committed the crime of violence (the sexual assault) before he committed burglary, the predicate offense. The habitual criminal statute requires life imprisonment for a person convicted and sentenced as a habitual criminal who was thereafter convicted of a felony that is a crime of violence. Here, the habitual criminal statute’s plain language unambiguously clearly provides that the sequence of convictions rather than the commission of the offenses controls. Fields was convicted of burglary and adjudicated a habitual criminal in 1995 and was convicted of the charges in this case in 2019. He was therefore properly sentenced.
The judgment was affirmed.