Supreme Court Overturns Conviction of Colorado Man Under Habitual Offender Statute
Troy Fields received extensive sentences following his conviction for kidnapping, sexual assault, and multiple violations under a state habitual offender law.
The U.S. Supreme Court has overturned a Colorado man’s conviction under a habitual criminal law, instructing a state appeals court to examine the case anew in light of a ruling made by the justices last year.
A habitual criminal statute increases the sentence for individuals found guilty of multiple offenses.
This recent ruling from the U.S. Supreme Court followed the establishment of guidelines in Erlinger v. United States, which outlined how trial courts should assess prior convictions in habitual criminal cases.
The Armed Career Criminal Act, established in 1984, was a response to concerns that a limited number of repeat offenders were responsible for a disproportionately high volume of crime.
Related Stories
The Supreme Court returned the case to the Colorado Court of Appeals for “further consideration in light of Erlinger v. United States.”
All justices were in agreement, and the U.S. Supreme Court did not provide its reasoning for the decision.
The Fields case traces back to 1994 when a woman identified in legal documents as J.C. became a victim of kidnapping, sexual assault, and robbery in her residence. The investigation made little progress until 2017, when detectives reexamining cold cases discovered DNA from the case file matched that of Fields, leading to charges against him.
Fields received concurrent sentences of 96 years for kidnapping and life imprisonment for sexual assault.
For a conviction under the state statute, jurors needed to ascertain that Fields had prior criminal convictions. While jurors acknowledged prior convictions, they did not specifically determine that those convictions resulted from “separate and distinct criminal episodes,” as per the brief.
Fields contended that his conviction should be reversed because the Colorado Court of Appeals’ ruling supporting it was now inconsistent with the Erlinger decision.
“Colorado’s habitual-criminal framework applies to individuals convicted of certain previous offenses ‘arising from separate and distinct criminal episodes,’” the petition filed in September 2024 stated.
Before the Erlinger ruling, Fields argued before the Colorado Court of Appeals that the U.S. Supreme Court had indicated in Apprendi v. New Jersey (2000) that the Constitution “required the jury to establish that his prior convictions were brought and tried separately and arose from separate and distinct criminal episodes.”
The state appeals court disagreed, asserting that the prior conviction exception outlined in Apprendi “encompass[es] whether prior convictions were separately brought and tried and arose out of separate and distinct criminal episodes,” making the issues in the Fields case “legal matters for the court” to decide, according to the petition.
The court upheld the trial court’s determination that Fields was a habitual criminal, which resulted in quadrupling the maximum possible sentence. Fields then appealed to the Colorado Supreme Court, which refused to hear the case.
However, in Erlinger, the U.S. Supreme Court “definitively rejected the viewpoint of the Colorado court,” as noted in the petition.
Fields urged the high court to “vacate and remand this case in light of Erlinger,” due to “the clarity that the Fifth and Sixth Amendments demand a unanimous jury—not a judge—decide whether Mr. Fields’s prior offenses arose from separate and distinct criminal episodes.”
Colorado asserted in its brief that Fields’s habitual criminal conviction did not contravene the Constitution.
The U.S. Supreme Court stated in Washington v. Recuenco (2006) that “most constitutional errors” made by courts, including those concerning the Sixth Amendment, “can be harmless.”
“The claimed error in this case is no exception,” the brief continued.
Fields’s prior convictions for forgery, drug offenses, theft, and burglary occurred between 1987 and 1989 based on acts committed across two different jurisdictions.
“There is no reasonable chance that the jury would have concluded his prior convictions were part of a single criminal episode,” the brief indicated.
Fields’s attorney, Tobias Loss-Eaton from Sidley Austin in Washington, opted not to comment.
The Epoch Times reached out for a comment from Colorado Deputy Attorney General Jillian Price, but no response was received by the time of publication.
