People v. Sotade.

2025 CO 38. No. 25SA9. Colorado Criminal Justice Records Act—Statutory Interpretation—Venue—Ancillary Jurisdiction.

June 9, 2025

The supreme court held that the plain language of CRS § 24-72-305(7) of the Colorado Criminal Justice Records Act requires any show cause hearing regarding a denied records request to take place in the district court of the district where the records are located. Further, the court held that a district court outside of the district where the records are located cannot exercise ancillary jurisdiction to consider an application to show cause because ancillary jurisdiction is not available where there is a statute that specifically directs venue. Here, a district court outside of the district in which records were kept concluded that—although the plain language of the statute required a different venue—it could exercise ancillary jurisdiction to hold a show-cause hearing. The court concluded that this was error. Accordingly, the court made absolute the order to show cause and remanded the case for further proceedings in the district court.