Simple Assault Offenses

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Sample Jury Instruction on Unlawful Use of Physical Force by Facility Staff

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Sample jury instructions outlining when physical force is by facility staff is unlawful against a young person.

Sample Motion for Court Order Allowing Defense Counsel Access to the Scene for Evidence Collection

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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. 

Sample Motion for Court Order Allowing Defense Counsel Access to Youth Facility for Evidence Collection

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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.

Sample Motion for Subpoena Duces Tecum Or Order to Compel to the Division of Youth Services Regarding Discoverable Material Related to a Physical Restraint Incident

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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 Instruction on Adolescent Brain Development and Impulsivity in a Self-Defense Case

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Sample jury instructions on adolescent development in a self-defense case involving staff at a youth facility.

Sample Jury Instruction on Self-Defense for Children Under Colorado Law

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Sample jury instructions for a child acting in lawful self-defense under Colorado law. 

Sample Jury Instruction In A Self-Defense Against Facility Staff Case

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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.

Report on Colorado State-Owned and Operated Youth Centers: Detained and Committed Youth

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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.

Student Arrests in Allegheny County Public Schools: The Need for Transparency and Accountability

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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…

Bound & Broken: How DYC’s Culture of Violence is Hurting Kids and What to Do About It

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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…

Crime, Race and Juvenile Justice Policy in Perspective

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