Narrative Opinion Summary
The case involves an appeal by Michael A. McGuire against his conviction for first-degree sexual assault, second-degree assault, and menacing. The key legal issues revolved around the applicability of the marital rape exception under § 18-3-409, C.R.S. 1986, and a request for a mistrial due to alleged courtroom misconduct. McGuire argued that the sexual assault charge should be dismissed based on the marital rape exception, asserting that he was a putative spouse under § 14-2-111, C.R.S. 1987. However, the court rejected this claim, noting McGuire's awareness of his existing marriage, which negated any good faith belief in the subsequent invalid marriage. Furthermore, McGuire contended that a mistrial should have been granted due to the complaining witness's audible interruption during closing arguments. The court found no abuse of discretion by the trial court, which determined that the interruption did not warrant a mistrial as it did not meet the extraordinary circumstances threshold. Ultimately, the Colorado Court of Appeals affirmed the trial court's judgment, concluding that the legal arguments presented did not merit overturning the conviction or sentence.
Legal Issues Addressed
Marital Rape Exception under § 18-3-409, C.R.S. 1986subscribe to see similar legal issues
Application: The court determined that the marital rape exception did not apply because the defendant's marriage was invalid due to his existing marriage, negating any good faith belief in the marriage.
Reasoning: The court rejects this argument, stating that McGuire was aware of his existing marriage, negating any good faith belief in the invalid marriage.
Mistrial Due to Courtroom Misconductsubscribe to see similar legal issues
Application: The court held that a mistrial was not warranted as the trial court acted within its discretion in assessing the impact of the complaining witness's interruption on the jury.
Reasoning: The court states that the right to a fair trial includes protection from prejudicial audience demonstrations, but a mistrial is only warranted in extraordinary circumstances.
Putative Spouse Doctrine under § 14-2-111, C.R.S. 1987subscribe to see similar legal issues
Application: The court found that the putative spouse doctrine did not protect the defendant as he was aware of his existing marriage, preventing a good faith belief in his subsequent marriage.
Reasoning: He claims to be a putative spouse under § 14-2-111, C.R.S. 1987, which protects those who cohabitate in good faith believing they are married.