The Colorado Supreme Court stepped in on Monday in the long-running fight over the fallout from former state crime-lab analyst Yvonne 'Missy' Woods, ruling that the Colorado Bureau of Investigation (CBI) does not have to release data from all of Woods' cases to murder defendant Michael Clark — at least not on the route Clark used, Colorado Public Radio (CPR) reported. A district court had earlier ordered CBI to hand over the subpoenaed information; the Supreme Court found the district court erred and sent the case back for more complete findings.

Source: Colorado Public Radio (CPR)

Woods pleaded guilty in June to four felony charges over her DNA-testing misconduct and was sentenced in September to 10 years in prison. Clark subpoenaed records identifying other cases in which Woods used particular DNA testing methods, hoping the material would support a motion to dismiss his case on grounds of outrageous governmental conduct, CPR reported.

Source: Colorado Public Radio (CPR)

A procedural ruling, not the end of the fight

Under Colorado's Forensic Science Integrity Act, passed after the Woods allegations surfaced, defendants in affected cases have a right to discovery — but the Supreme Court said a defendant must first make that discovery request, and may subpoena records only after the request is rejected. Clark went straight to a subpoena, the court found, and he had neither received the required notice of wrongful action from the district attorney nor filed the pleading and court-order request the law requires. 'The Supreme Court's ruling was that the procedure had been wrong, but it did not tell the district court to reach a different outcome on the question of whether to order CBI to disclose the documents at issue,' said Adam Frank, one of Clark's attorneys, as reported by CPR.

Source: Colorado Public Radio (CPR)

Clark was convicted in October 2012 of the first-degree murder of Boulder city employee Marty Grisham, who was killed in 1994. Woods testified at his trial about DNA found inside a lip balm container at the scene; after the allegations against her became public, an independent laboratory retested the evidence. In April 2025 a Boulder district judge overturned Clark's conviction and he has been out on bond since. The Boulder district attorney's office itself supported vacating the conviction, citing the retest results, claims of juror misconduct and ineffective assistance of counsel. No retrial date is currently scheduled, CPR reported.

Source: Colorado Public Radio (CPR)

CBI objected to Clark's request as broad and burdensome, estimating it would take more than 2,000 staff hours and noting Woods worked on around 2,700 cases using the method in question. The Attorney General's office argued Clark was seeking to generate information from thousands of other cases to test a theory about CBI's DNA policies, rather than seeking identified evidence from his own case. CBI and the Attorney General's office declined to comment on the ruling, citing the ongoing matter, CPR reported. Wisevoter's summary of the ruling likewise records that the court found Clark bypassed required discovery protocols before subpoenaing CBI.

Source: Wisevoter, summarising the ruling

The ruling does not end the dispute: it leaves open whether CBI must disclose some or all of the information if Clark follows the Act's process and the district court makes fuller findings — a question now watched by defendants in hundreds of other Colorado cases touched by the Woods scandal.