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April 12, 2012

Life Sentences in Colorado Sex Offender Cases Go Too Far - Return Discretion To The Trial Judges

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The recent conviction and mandatory life sentence of Broomfield High School wrestling coach Travis Masse demonstrates why the 1998 Colorado Lifetime Sex Offender Supervision Act goes too far.

A jury convicted the 29-year-old former teacher Tuesday of sexual assault on a child by someone in a position of trust, determining that he had sexual contact with the student on three occasions after the two exchanged sexually explicit text messages. There was no evidence that the relationship was anything but consensual - to the contrary there was no evidence of force.

As an experienced Colorado Criminal Defense Lawyer - I have discussed this law with many other practicioners - on both sides of the issue. There is considerable agreement among these men and women that Colorado sex-offender sentencing laws, which are the toughest in the nation, take away the primary justification for the election and periodic review of our judges - the responsibility for sentencing those convicted of crime.

The Colorado Sex Offender Sentencing system should be returned to a sentencing scheme - like almost all other crimes - that places on judge's shoulders the responsibility to make the diffcult calls.

The District Attorney determines how to charge criminal cases. If the DA adds enhancers such as the Position of Trust label and Pattern of Abuse allegation to the sex crime charged - and there is a conviction - across the board - without distinguishing one case from another - it means a mandatory life sentence for the defendant,... a judge loses complete control of the sentencing decision.

This must end.

Posted by H. Michael Steinberg | | Email This Post

December 25, 2011

Colorado Supreme Court Cases Enhances Penalty for "Pattern Type" Sexual Assault Cases C.R.S. 18-3-405.3.

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A new Colorado case issued by the Supreme Court of Colorado clarifies the law in Colorado in Sexual Assault on a Child Cases where there are multiple instances of conduct constituting a pattern. The decision allows for consecutive sentences for each act notwithstanding the fact that there has been a single victim.

Colorado's sexual assault statutes authorize the possibility of greater punishments for sexual crimes against children that are committed "as a part of a pattern of sexual abuse."

Two cases, "Colorado v. Simon" and "Colorado v. Tillery" were consolidated for the Supreme Court's review in that they both involve interpretation of Section C.R.S. 18-3-405.3. The common issue presented by these cases was whether the statutory provisions and principles of double jeopardy permit only one class 3 felony conviction and sentence for a single "pattern" of abuse that comprises two or more incidents of sexual assault, or whether each separate act of sexual assault that composes a single "pattern" of abuse which may be elevated to a class 3 felony.

In "Simon," one division of the court of appeals held that section 18-3-405.3(2)(b) and double jeopardy principles prohibit the trial court from entering multiple class 3 convictions and sentences for Simon's ten counts of sexual assault on a child by one in a position of trust, where those acts composed a single pattern of abuse against one victim.

In "Tillery," a different division of the appellate court disagreed with the reasoning in "Simon." Finding no double jeopardy violation, the court upheld Tillery's class 3 convictions under 18-3-405(2)(d).

Upon review, the Supreme Court held that these statutes unambiguously allow each separately charged incident of sexual assault to be elevated to a class 3 felony, where each incident is committed as part of a pattern of sexual abuse. Furthermore, the Court held that these statutes, construed according to their plain language, do not violate the double jeopardy protection against multiple punishments under either the U.S. or the Colorado Constitution

Court Summary of the Case

December 19, 2011

No. 09SC665 - People v. Simon & No. 09SC1043 - Tillery v. People - Criminal Law - Sexual Assault on a Child, and Sexual Assault on a Child by One in a Position of Trust, as a Part of a Pattern

The supreme court holds that sections 18-3-405(2)(d) and 18-3-405.3(2)(b) unambiguously allow each separately charged incident of sexual assault on a child, or sexual assault on a child by one in a position of trust, to be elevated to a class 3 felony, where each incident is committed as part of a pattern of sexual abuse. The supreme court further holds that these statutes, construed according to their plain language, do not violate the double jeopardy protection against multiple punishments under either the U.S. or the Colorado Constitution.

The supreme court therefore reverses the court of appeals' decision in People v. Simon, Case No. 09SC665, reinstates Simon's ten class 3 felony pattern convictions and sentences, and remands to the court of appeals for consideration of the remaining issue raised by Simon on appeal. The supreme court affirms the court of appeals' decision in Tillery v. People, Case No. 09SC1043, and remands with directions to return the case to the trial court for resentencing in accordance with the court of appeals' decision.

Posted by H. Michael Steinberg | | Email This Post

November 23, 2011

Colorado DA Nets Another Sexting Suspect for Internet Luring

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ELLICOTT, COLO.is a very small town in Colorado on the Eastern Plains just east of Colorado Springs.

In that small jurisdiction a School District board member has just been arrested for allegedly sexting a 14-year-old boy.

Thirty-seven-year-old Stefanie Dickinson was arrested Sunday for Internet Luring of a Child, a class four felony.

As the Schools Board's treasurer she had access to the alleged victim in the case a 14-year-old boy, who attends Ellicott High School

The young boy allegedly began receiving text messages from Dickinson sometime in August after returning from a trip with her and her family to Lake Meridith in Ordway

The boy's sister found the texts while he was at football practice. It said many of them are "sexual in nature" and reference "oral sex" among other things.

One reads "I will work on not being scared so something can happen," while another says "You can't tell anyone about this at all because I could lose my family."

H. Michael's Take

While there is no Colorado specific crime titled Sexting - the crimes that can be charged in a case like this are very serious. One possibility is the Colorado Sex Offender Crime of Sexual Exploitation of a Child. Another is Internet Luring - a form of solicitation of a minor to engage in sex. Just the attempt is a very serious felony in Colorado.

The increasing attention to Internet and Electronic Based communication in our modern world - has led to the use of these resources to engage in the more recognizable sex offender crimes that have always existed. Law enforcement's resources to track and to fullly investigate and charge these crimes is on the rise in terms of the gathering of intelligence - organization and pooling of Federal and State funds and and the sharing of technology

Posted by H. Michael Steinberg | | Email This Post

October 5, 2011

A Recent - 2011 Colorado Case - Points Up the Lack of Analysis in the Sentencing of Colorado's Sex Crimes Cases

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An article - written by Monte Whaley - appearing in the Denver Post in August of 2011 entitled - "Sentencing disparities in child-sex-assault cases point to double standard" confronts the insanity of Colorado's Sex Offender Sentencing Laws

The article began with this statement "Women in Colorado convicted of sexually assaulting a child in their care are far less likely to go to prison than men sentenced for the same crime."

The Post did a comprehensive analysis of publicly available sentencing data provided by the Colorado Judicial Branch.

The data demonstrated that "of the 2,128 men convicted of sexual assault on a child by a person in a position of trust from 2006 through 2010, more than 50 percent were sent to prison."

However, "of the 79 women convicted of the same felony offense, 38 percent went to prison. A little more than 39 percent of female defendants in that same period 31were put on intensive supervised probation. Less than 35 percent of men were given the same sentence."

Analysis Focused on male and female teachers, coaches, babysitters and others who are considered to be in a sexual assault on a child and who are in a "position of trust."

With women, the victim is often a young or teen male in her charge, and too often the abuse is seen as less traumatic and almost a badge of honor for the boy, said forensic psychologist Katherine Ramsland.

Several studies uncovered by the Post demonstrate that males molested by female caregivers run a huge risk of becoming sex offenders in adulthood... and that women who molest boys are most likely victims of abuse themselves.

Woman-on- boy crimes are not reported at all, due in part to the media.

Prosecutors say they focus on recividism rates:

All things being equal including prior history - prosecutors focus on the likelihood of recidivism.

The Post story referenced a 2005 study shows that females convicted of a sexual offense repeat the same offense only about 1 percent of the time. The recidivism rate for male sex offenders is 13.4 percent.

Larimer County DA Larry Abrahamson points to the criteria that DA's view as important.

"You look at the charges, you look at the level of threat that individual is causing the community and if that person is subjecting the victim to pretty significant trauma. You have to look at all of those factors," Abrahamson said.

The Colorado SOMB ( Sex Offender Management Board ) psycho-sexual evaluation is critical here.

In Colorado - in negotiating this deadly road - the Colorado criminal defense attorney - attempting to defend a clear case of sexual assault on a child - will refer their clients to a State Certified Colorado Sex Offender (SOMB Approved) evaluator. The purpose of this intense and difficult evaluation is to help determine the true "risk" a sex offender presents to the community. The report - generated by this evaluation - have a great bearing on the negotiating process.

"Those responses can determine what kind of punishment level you are seeking," Abrahamson said.

H. Michael's Take

All Colorado criminal defense lawyers who defend these cases are locked into the draconian Colorado sex offender laws passed in the late 1990's.

These laws, opposed by many - if not most - of Colorado District Court judges - take away the right of a judge to utiliize his/her experience and given authority to determine a sentence commensurate with the nature of the crime. These laws lock judges into a "one size fits all" method of pursuing and convicting sex offenders, both men and women.

Posted by H. Michael Steinberg | | Email This Post

August 26, 2011

Colorado Sex Offender"Indeteminate" Sentencing System Releases Few Inmates Once Sentenced to Prison

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Every year, the Colorado Sex Offender Management Board (SOMB) is tasked with the responsibility of reporting on the success or failure of the draconian sentencing structure the Colorado State Legislature Created in 1998.

According to the Colorado Sex Offender Management Board's latest report, 1,651 people had been handed indeterminate "life sentences" sentences since the change in state law in 1999.

Of the 1,651, only 66 - or 4 percent - have been paroled. That's correct, 4%.court ordered discharge.

More specifically - the brakdown is -

...of the 1,651 offenders sentenced to prison under the lifetime supervision provisions for sex offenses, 117 have discharged their sentence through June 30, 2010:

• 49 offenders released by court order;
• 36 offenders released to probation;
• 24 offenders died;
• 4 offenders released on an appeal bond;
• 3 offenders had their sentence amended then released per Martin Cooper law; and
• 1 offender released from the Youthful Offender System (YOS).

The reason for the refusal to parole is that it is just not popular for the Colorado Parole Board - the decisionmakers in granting parole to these offenders,- to release into society someone who has been sentenced to the Colorado Department of Corrections for life.

Even Judge's - if asked privaitely - will tell you that the system is flawed and destructive as was the case in the recent sentencing of a Colorado Wrestling Coach convicted by a jury of having relations with a student.

Clearly punishment was expected in such a case, but a life sentence, with only a 4% chance of parole - is not contemplated in a just society.


Even Inmates Who Have Paroled Have Not Coe Close To DIscharhging Their Parole

According to CRS 18-1.3-1006, the period of parole for any sex offender convicted of a class 4 felony shall be an indeterminate term of at least ten years and a maximum of the remainder of the sex offender's natural life. The period of parole for any sex offender convicted of a class 2 or 3 felony shall be an indeterminate term of at least twenty years and a maximum of the remainder of the sex offender's natural life.

Therefore, no discharge hearings have been held to date and are not expected for several more years.

Taking Stock of the Hysteria

It is unclear whether the Colorado State Legislature will take a more reasoned look at this incredibly harsh and non-rational approach to this area -- the No-Cure Model is flawed and follows the well known Colorado knee jerk reaction to the hysteria that follows these cases in the media, - but I have hope that a more rational system is not too far off - I have already seen the Courts pay more attention to the ongoing research which gives me hope for the future. A future that leaves a life sentence for those individuals who committ captial crimes. H. Michael Steinberg

Posted by H. Michael Steinberg | | Email This Post

July 31, 2011

The Harsh Reality of Colorado's Sex Offender Laws Hit Hard - A Colorado High School Wrestling Coach Receives Life In Prison

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On Monday, July 25, 2011 A Broomfield County Colorado Wrestling Coach was Sentenced to life in prison after a jury trial which ended in convictions of for Sexual Assault On A Child by a Person in a Position in Trust and Sexual Assault on a child - Pattern of Abuse (more than two incidents).

The verdict related to his sexual assault of a 15-year-old high school girl who was manager of his wresting team. Prosecutors presented evidence at trial that Masse had sex with the girl on several occasions and sent as many as 8,900 text messages to the girl - many of them sexually explicit - between December 2008 and February 2009.

Judge Thomas Ensor, the presiding judge over the May 2011 trial - was compelled by Colorado's mandatory life in prison laws - to sentence Masse to 10 years to life with 20 years' mandatory parole for the first charge, and six years with 20 years' parole for a second offense

At the sentencing hearing Judge Ensor said " This is like a Greek tragedy," "You had everything going for you. But you have a fatal flaw. You found the weakest in the herd, separated her out, groomed her, made her comfortable and then ... you were able to complete what you wanted to do."

Travis Masse, the convicted coach, was a well-respected, award-winning high school wrestling coach who led his young athletes to the Class 4A state wrestling championship in 2008-09. The flaw Judge Ensor spoke of was Masse's predilection for exploiting young women.

Travis Masse, after the verdict did THEN take a plea bargain in a second case - to unlawful sexual contact coercing a child involving Masse's texts and request for nude photos from another female high school student. He was sentenced to two years with six years of parole for that offense, to be served concurrent with the other sentences.

H. Michael's Take:

It is impossible to know whether a plea bargain that could have avoided the life sentences imposed on this man prior to his decision to take the case to trial. It is also impossible to know why he believed the jury would possibly believe the young victim was not telling the truth to the jury at the trial. This case may serve as a warning to all who face these charges and who throw caution to the wind and take these charges to trial.

This author will - over the next several weeks - try to learn more of the "back story" of this case as to what - if any - plea bargain may have been offered by the Broomfield County District Attorney's office. If none was offered - it may be more clear why the case was tried to a jury.

Posted by H. Michael Steinberg | | Email This Post

January 14, 2011

Lack of Consent to Teenage Sexual Contact No Defense for NFL Football Player

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Sex offender registry awaits NFL's Lawrence Taylor

N.Y. (AP) -- Former NFL star Lawrence Taylor admitted in court to paying a 16-year-old runaway for sex as he pleaded guilty to sexual misconduct and patronizing a prostitute.

The 51-year-old ex-linebacker, who led the New York Giants to Super Bowl titles in 1987 and 1991, will serve six years' probation and must register as a sex offender.

"She told me she was 19," Taylor, standing with his hands clasped behind him, said Thursday in court as he admitted having intercourse with the prostitute, who turned out to be a Bronx runaway. Taylor said he now knows the girl was 16 and legally incapable of consent.He said he paid her $300.

Harry Carson, a former teammate and fellow Hall of Famer, was in the courtroom and gave Taylor a supportive handshake when he arrived.

Prosecutor Patricia Gunning said the plea deal was acceptable in part because Taylor had assisted in investigations into human trafficking since he was charged. Another prosecutor, Arthur Ferraro, said outside court that Taylor "was of assistance in the field of human trafficking in several jurisdictions and with federal authorities."

Defense attorney Arthur Aidala said that "obviously" included a federal case against the man charged with being the 16-year-old's pimp.

Aidala said Taylor decided the plea bargain was in everyone's best interest.

"He could have taken a much more aggressive road, but he decided it was in the best interest of he and his family and the young woman to put this behind him," Aidala said. "Mr. Taylor's not proud of what happened. ... He patronized a prostitute and that prostitute happened to be under the age of 17."

Taylor had resisted a plea deal for months after pleading not guilty to third-degree rape, patronizing a prostitute, sexual abuse and endangering a child.

Prosecutors said in December that Taylor had been offered a six-month jail term and 10 years' probation in exchange for pleading guilty to a felony. Aidala had called that offer unacceptable but said he would listen to any other offers.

Two members of the Giants' 1991 Super Bowl team are behind bars. Mark Ingram Sr., a star receiver, is spending nearly 10 years in federal prison for money laundering, bank fraud and bail jumping. And the electrifying kick returner Dave Meggett was sentenced last year to 30 years for criminal sexual conduct and burglary.

Taylor's trial would likely have started within a few weeks.

He was arrested May 6 after the underage girl's uncle contacted New York City police. Officers from Ramapo woke him at a Holiday Inn in Montebello.

Police said he was cooperative and no drugs were found in the room, although a bottle of alcohol was. Taylor has a history of drug offenses but has been to rehab and his lawyer says he has been sober for years.

"The whole L.T. persona, to me that's an act," Carson said before court. "I'm here for Lawrence Taylor. I'm not here for L.T. ... Once he went through some of the stuff he went through, he realized that was a hindrance to himself and his family."

In court, Carson, sitting in the front row of the gallery, reached over a low wall into the defendant's area and straightened Taylor's overcoat collar.

In a related case, federal prosecutors in Manhattan filed a complaint last year against a man who is accused of acting as the girl's pimp. Court papers in that case say Taylor admitted to sex acts with the girl but said he was told the girl was 19.

Ramapo police Chief Peter Brower said after Taylor's arrest that ignorance of a minor's age is not a defense to third-degree rape.Aidala had claimed that Taylor's arrest was illegal because police did not have a warrant when they burst into his suburban hotel room in May. Prosecutors said no warrant was required and state Supreme Court Justice William Kelly rejected the claim. But he granted a pretrial hearing on whether statements Taylor made upon his arrest were admissible. Aidala said in December he was relishing the chance to cross-examine the arresting police officers.

Taylor was inducted into the Pro Football Hall of Fame in 1999. A fierce, athletic linebacker, he redefined his position and was selected to the NFL's 75th Anniversary All-Time Team.

In 2009, he competed in ABC's "Dancing With the Stars." He had also been a spokesman for the NutriSystem weight-loss company, but he was dropped after his arrest.

Sentencing is March 22. That same day, state Supreme Court Justice William Kelly will determine what level of sex offender status Taylor will have. Aidala said he will suggest Level 1, which he said would mean checking in once a year with local police.

Aidala said he would seek to have Taylor's probation transferred to Florida, where the former player now lives.

H. Michaels Take

Here is a prime example of the unfairness of ancient statutory rape laws that have destructive consequences today. A young woman today can lie about her age, forge her driver's license, dress and act as if she is much older - have consesual sexual relations with an adult male and the law will NOT take into account ANY of those factors in proving the crime of Statutory Rape.

By law -- a child cannot consent under any circumstances. Therefore judges and juries are prevented - by operation of these laws - from exercising their discretion to take into account the surrounding circumstances of the contact.

England‟s first statutory rape offense, enacted in 1275, protected only females aged eleven and under. Some three hundred years later, during the reign of Elizabeth I, the protected class was reduced to females nine and under. The American colonies largely imported the English statutory scheme.6 "The idea behind such laws at the time was less about . . . [protecting the female from sexual exploitation,] and more about protecting white females and their premarital chastity--a commodity--as property."

As United States Chief Justice William Brennan explained, "[b]ecause their chastity was considered particularly precious, those young women were felt to be uniquely in need of the State‟s protection." From this "exaltation of female chastity," a statutory rape victim being unchaste, promiscuous, or not a virgin evolved into a defense that was soon "codified in every state,

It is time to modify and bring up to date these anacronistic laws...HMS

Posted by H. Michael Steinberg | | Email This Post

December 31, 2010

DNA, SANE Nurse - Expert Analysis in Colorado Sexual Assault Conviction May Have Made the Difference

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The Following verdict in a Colorado Sexual Assault Trial demonstrates the many levels of testimony that can be admitted in a trial .. it is instructive at many levels for that reason

Jury convicts Valdez of sex crimes Thursday, Dec 30th, 2010

DEL NORTE, Colorado ・A Rio Grande County District Court jury deliberated for four hours before the criminal incest trial of Arthur Valdez ended with a verdict of guilty on two counts.

Valdez, 39, has an address in Alamosa and is reportedly a registered sex offender with a previous felony conviction, which qualifies him for enhanced sentencing for a repeat offense.
A hearing regarding the habitual sentencing enhancer for Valdez will be held Jan. 12, 2011. His sentencing is scheduled for Feb. 9.

Assistant District Attorney Crista Maestas told the jury that, throughout the trial, they had heard testimony from the alleged victim; school officials who knew the young woman better than her own family did; expert testimony from a Colorado Bureau of Investigation (CBI) criminal laboratory analyst; the Sexual Assault Nurse Expert (SANE) who performed a physical exam on the girl, and from others who investigated the case.

Responding to defense allegations that the girl had lied and set her father up as an act of revenge, Maestas asked the jury, What did she (the alleged victim) get from this?・

He ended up homeless, she graduated and not a single family member was there. She had to undergo a horrible exam and tell her story repeatedly "why in the world would she possibly make this up?"

The defense claimed the alleged victim wanted revenge because she didn't have the relationship she wanted to have with her father. The defense admitted Valdez was not a model father to his daughter, but said he was not on trial for that. They claimed Valdez thought his daughter would try to set him up and deliberately stayed away from her or had others with him when they were together.

Defense attorneys claimed a CBI Analyst findings from a sample on a pair of underwear was inconclusive for bodily fluids and only uncovered skin cells.

Maestas countered that the analyst reported that they were enucleated cells of some sort. The CBI also reported that the YSTR analysis matched all 11 sites. The YSTR is a specific DNA match test for the presence of the male or Y chromosome and the identity of the Y.

With all sites matching, the analyst reported the DNA sample could only have come from the defendant or one of his paternal male relatives.


H. Michael's Take

In this case you have a classic frontal attack on the victim's credibilit. The defense lawyer did an excellent job and had much to work with in this case in the area of witness credibility. However, notice the prosecution's expert forensic evidence attack that went unrebutted for the most part.

The SANE nurse:

Sexual Assault Nurse Examiner (SANE) Programs were created whereby specially trained forensic nurses provide 24-hours-a-day, first-response care to sexual assault patients in either hospital or non-hospital settings.

These nurses go well beyond the care of the alleged victims - they collect forensic evidence traditionally performed in hospital emergency departments. They document injuries and physical evidence, they document the alleged victim's statements and their demeanor

The CBI - Colorado Bureau of Investigation Testimony

Here - even though the sample of the DNA evidence was questiionable - it was admitted and was most likely used by the jury to push the case over the beyond a reasonable doubt standard

Bottom Line: Defending an allegation of sexual assault is difficult under the best of circumstances -- defending such a case without expert testimony to counter the State of Colorado's nearly endless resources -- is daunting -- a war chest of defense funds is often necessary to mount an effective defense at times.

Posted by H. Michael Steinberg | | Email This Post

December 7, 2010

Utah Sex Crimes Law Finds Rights of Law Enforcement Greater Than Privacy Interests

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Divulge Online IDs, Court Tells Utah Sex Offenders

The Story:

(CN) - The 10th Circuit upheld a Utah law that forces sex offenders to hand over names they use to send e-mails and instant messages.

A Utah resident, convicted by the military for sex crimes against a minor, filed suit anonymously to contest the law, which requires sex offenders to identify all "Internet identifiers," defined as "any electronic mail, chat, instant messenger, social networking or similar name used for Internet communication."

Utah amended the law, which originally required sex offenders to disclose their passwords, after a federal judge ruled that provision infringed on Doe's First Amendment rights.

The 10th Circuit in Denver, which issued its opinion in October but recently corrected the filing, ruled that law enforcement investigations into sex-related crimes trumped the plaintiff's claims under the First Amendment because of a "compelling interest."

Judge Monroe McKay, writing for the three-judge panel, noted that sex offenders were still allowed a degree of online anonymity since law enforcement limits its use of the information to criminal investigations.

"Although there is a possibility that a government agent would have access to Mr. Doe's identity at the time he was speaking - as, for example, if an undercover sought him out in a chat room in the course of investigating a sex crime - we are not persuaded that this possibility imposes a constitutionally improper burden on speech," McKay said.

The judge also rejected claims that the law constitutes an illegal search and seizure barred by the Fourth Amendment or the ex post facto clause of the Constitution.

"Looking closely at Mr. Doe's argument on this issue, it seems clear that his contentions depend entirely upon his argument that the Utah statute would allow impermissible public disclosure of his internet identifiers, thereby destroying his right to anonymous speech," McKay wrote. "However, because we conclude that Utah's registration statute does not violate the First Amendment, we hold that the effect of the new disclosure requirements is not substantial enough.

H.Michael's Take

Often - in the hysteria that marks allegations of sex crimes - no matter how minor -individual rights are eroded. I have represented many people - young and old -who have become caught up in the dominance of the porn industry on the interent. These people most often have no criminal history - are naive in the ways of the world and the internet and often become wholly enveloped in pronographic sites and chat rooms. They are no match for the seduction of the "net"and after they have been "stung" by law enforcement -- their lives are marred forever by their identification as sex offenders.

These people need our help - not our condemnation. This Utah law - while a small step in a much larger "movement" signifies the rebalancing of the rights of those who bear this lable - some - for the rest of their lives. It is a step in the wrong direction in my opinion - as each individual should be viewed in the context of their lives...

Posted by H. Michael Steinberg | | Email This Post

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