20SC399 - Rojas v. People

Applying this holding to the case before it, the supreme court concludes that the challenged evidence is an extrinsic act that implicates the defendant’s character, and its admissibility is therefore governed by CRE 404(b) and Spoto. But because the trial court admitted the evidence under the doctrine of res gestae, it didn’t conduct a CRE 404(b) analysis and didn’t provide the requisite procedural safeguards. This constituted error. And because the error was not harmless, the judgment of the court of appeals, which affirmed the defendant’s convictions, is reversed, and the case is remanded…