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Colorado justices send CBI DNA-record dispute back for more findings

The state Supreme Court ruled that a Boulder judge did not adequately justify ordering the Colorado Bureau of Investigation to provide Michael Clark’s defense with records from about 900 cases handled by former analyst Yvonne “Missy” Woods. The records will not be turned over under the current order, but the dispute returns to district court for further consideration.

Colorado justices send CBI DNA-record dispute back for more findings

The Colorado Supreme Court on Monday overturned a Boulder County judge’s order requiring the Colorado Bureau of Investigation to provide Michael Clark’s defense team with DNA-related records from hundreds of other cases involving former CBI analyst Yvonne “Missy” Woods.

The unanimous ruling does not resolve whether the defense may ultimately obtain the material. Justice William Hood wrote that the district court’s order went beyond the governing criminal-procedure rule and was “at best, premature.” The case now returns to the lower court, which must make more complete findings.

Clark’s lawyers subpoenaed the records in 2025, arguing that Woods’ work in cases from roughly the same period as Clark’s could help show a pattern of misconduct or tolerance of faulty analysis at the state crime lab. CBI estimated the request covers about 900 cases.

The state Attorney General’s Office, representing CBI, opposed the request, arguing that analyses unrelated to Clark’s case were not relevant and that gathering them would burden the agency. Boulder County District Judge Nancy Salomone ruled in February that records from Woods’ other cases might be relevant, particularly to a defense motion alleging “outrageous governmental conduct” at the lab. Clark’s motion to dismiss the murder charge, filed in May, remains pending.

Woods pleaded guilty in June to four felony charges involving the alteration or deletion of data in numerous cases. She was sentenced in September to 10 years in prison. CBI has acknowledged finding 1,045 problems in her past work, but the agency and prosecutors have said an internal review did not identify problems in her work on Clark’s case. CBI leadership has also said it has found no evidence that Woods’ misconduct led to anyone being wrongly imprisoned.

Woods’ DNA analysis and testimony helped secure Clark’s 2012 conviction for the 1994 Boulder murder of Marty Grisham. Clark was sentenced to life without parole. After independent testing in 2025 found inconsistencies in Woods’ original analysis, Boulder County District Attorney Michael Dougherty agreed the conviction should be vacated. Clark was released on bond in April 2025 after serving 12 years and is awaiting a second trial.

Clark’s attorney, Adam Frank, said he viewed the Supreme Court’s decision as a temporary setback rather than a loss. “The Supreme Court did not disavow the district court’s ruling,” he said, adding that the justices instead asked the lower court to make additional findings.

The ruling leaves the defense’s effort to obtain broader records unresolved as the case proceeds in Boulder County.

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