Post-Charge and Trial Issues Archives

Investigative Resource Repository

Idaho v. Dalrymple – Case Resources

1) State’s Motion in Limine for Non-Disclosure
2) Memorandum in Support of State’s Motion in Limine for Non-Disclosure
3) State’s Motion to Re-Open Previously Filed and Ruled Upon Motion in Limine for Non-Disclosure
4) State’s Objection and Brief in Opposition to Defendant’s Motion to Suppress
5) Defense’s Brief in Support of Motion to Suppress
6) Court’s Ruling on Defense Motion to Suppress

May 2024

Investigative Resource Repository

Court’s Ruling on Defense Motion to Suppress (Idaho v. Dalrymple)

Trial court’s opinion denying defendant’s motion to suppress in a murder-sexual offense case.

May 2024

Investigative Resource Repository

State’s Objection and Brief in Opposition to Defendant’s Motion to Suppress (Idaho v. Dalrymple)

Prosecution’s response to defense’s claim of Fourth Amendment violation in a murder-sexual offense case. The State attached, as an exhibit, the Minnesota trial court’s ruling on this issue in State v. Westrom. See Minnesota Supreme Court’s opinion in the Westrom Case, upholding the trial court’s ruling here.

April 2024

Investigative Resource Repository

Defense’s Brief in Support of Motion to Suppress (Idaho v. Dalrymple)

Suspect’s hair that was found from the crime scene of a murder-sexual offense case was subjected to single nucleotide polymorphism extraction and genealogical search. Defense claims these techniques violate the defendant’s Fourth Amendment and the State of Idaho’s privacy rights of a suspect.

April 2024

District Attorney’s Office, Denver, CO

Colorado v. Groshart – Case Resources

1) The People’s Ex Parte Submission & Request for Ex Parte, In Camera Hearing
2) People’s Motion to Admit Evidence of Another Act of the Defendant
3) People’s Response to Defense Motion to Dismiss for Violation of Right to Speedy Trial
4) People’s Response to Defense Motion to Dismiss Due to Outrageous Government Conduct
5) People’s Notice of Intent to Not Mention the Use of Forensic Genetic Genealogy at Trial

March 2024

District Attorney’s Office, Denver, CO

People’s Notice of Intent to Not Mention the Use of Forensic Genetic Genealogy at Trial (Colorado v. Groshart)

Prosecution proposed stipulation. Prosecution’s notice of intent not to produce evidence of Forensic Genetic Genealogy investigative process to develop investigative leads.

March 2024

Investigative Resource Repository

State’s Motion to Re-Open Previously Filed and Ruled Upon Motion in Limine for Non-Disclosure (Idaho v. Dalrymple)

Prosecution’s follow-up motion regarding non-disclosure of Investigative Genetic Genealogy (IGG) process in light of a new appellate decision.

February 2024

District Attorney’s Office, Denver, CO

People’s Response to Defense Motion to Dismiss Due to Outrageous Government Conduct (Colorado v. Groshart)

Prosecution’s response to defendant’s claim that the covert collection of a DNA sample from defendant was “outrageous government conduct.”

January 2024

District Attorney’s Office, Denver, CO

People’s Response to Defense Motion to Dismiss for Violation of Right to Speedy Trial (Colorado v. Groshart)

Prosecution’s response to defendant’s speedy trial claim.

December 2023

District Attorney’s Office, Denver, CO

People’s Motion to Admit Evidence of Another Act of the Defendant (Colorado v. Groshart)

Prosecution seeks admission of incriminating items the defendant in this 2004 sexual assault case possessed during an arrest in 2007. Argument and analysis of 404(b) type of evidence in context of items possessed at another time.

September 2023

Category: Post-Charge and Trial Issues