Background
Colorado charged Shawn Spomer in June 2021 with two counts of introducing contraband into a detention facility. While those charges remained pending, Spomer was arrested, extradited to Ohio, and sentenced there in June 2022.
Spomer later sought final disposition of the Colorado charges under the Interstate Agreement on Detainers Act. The Weld County District Court initially took no action, finding that he had not strictly complied with the IAD. After his return to Colorado in May 2023, Spomer moved to dismiss, arguing that he had complied with the IAD and that the State had missed its trial deadline. The court denied the motion. Spomer then pleaded guilty to one contraband count in exchange for dismissal of the other and a stipulated two-year probationary sentence.
The Court’s Holding
The Colorado Court of Appeals dismissed the appeal. It held that Spomer waived his claimed IAD violation by entering a guilty plea after the district court denied his motion to dismiss.
IAD rights are nonjurisdictional and may be voluntarily waived. Because Spomer did not challenge the validity of his guilty plea, the plea waived appellate review of issues arising before it, including the alleged IAD violation. Waiver extinguishes any asserted error and forecloses appellate review.
Key Takeaways
- A valid guilty plea generally waives appellate review of pre-plea IAD claims.
- IAD rights are nonjurisdictional and nonconstitutional, so a defendant may voluntarily waive them.
- A defendant seeking review after a guilty plea must overcome the plea’s waiver effect; Spomer did not challenge his plea’s validity.
Why It Matters
The decision reinforces that an alleged failure to comply with the IAD’s timing requirements does not survive an otherwise valid guilty plea. Defendants who intend to preserve an IAD issue for appellate review must account for the waiver consequences of pleading guilty.