Simple Assault Offenses
Sample jury instructions outlining when physical force is by facility staff is unlawful against a young person.
A sample motion in a youth facility assualt case asking the court to order access to the facility for evidence collection, including viewing the scene and taking photographs of the facility.
A sample motion requesting the court to compel Colorado’s Department of Youth Services to comply with a subpoena duces tecum regarding records related to excessive force and physical abuse in their facilities.
A sample motion asking the Court to issue a subpoena duces tecum to the state youth department for material reports, documents, witness information, and video survelliance regarding an incident of physical restraint.
Sample jury instructions on adolescent development in a self-defense case involving staff at a youth facility.
Sample jury instructions for a child acting in lawful self-defense under Colorado law.
Sample jury instructions for self-defense in a case involving a young person defending themself against facility staff’s unlawful use of force or physical restraint against a youth at a residential facility.
Semi-annual report from January-June 2023 from the Colorado Division of Youth Services on reported number of physical and sexual assaults, number of facility staff, and other conditions of confinement data in its state-run residential facilities for detained and committed young people.
From the introduction: “One of our goals in producing this report is to inform school administrators, board members, and parent and student stakeholders, giving details about which groups of students are disproportionately arrested and about the gaps that exist in data reporting. We also want to provide guidance on how to address these issues. We…
This policy report features interviews of young people who have been incarcerated in youth facilities in Colorado and details the harmful conditions and culture in these programs. From the Executive Summary: “Despite a mission of rehabilitation rather than punishment, the culture of the Colorado Division of Youth Corrections (DYC) is plagued by punitive practices that…