Justia Colorado Supreme Court Opinion Summaries

Bradford Wayne Snedeker was convicted of various fraud and theft charges in two separate Boulder County District Court cases. In the first case, he was sentenced to four years in prison for securities fraud and a consecutive one-year term of work release plus twenty years of probation for theft. In the second case, he was sentenced to fifteen years of probation for theft, to run concurrently with the first case's sentence. After serving the prison term, Snedeker argued that his sentences were illegal under the ruling in Allman v. People, which held that a court cannot impose both imprisonment and probation for different offenses in the same case. The district court agreed that the first case's sentence was illegal and ordered resentencing but found the second case's sentence legal.The Colorado Court of Appeals reviewed the Fraud Case and affirmed the district court's resentencing decision. Snedeker then petitioned the Supreme Court of Colorado for review, arguing that reimposing the original probationary sentence after serving the prison term still violated Allman and that imposing concurrent prison and probation sentences in separate cases also violated Allman.The Supreme Court of Colorado held that when a sentence is illegal under Allman and the defendant has already served the prison portion, the court can reimpose a probationary term because probation remains a legal sentencing option. The court also held that it does not violate Allman to sentence a defendant to imprisonment in one case and probation in a separate case. Thus, the court affirmed the court of appeals' judgment in the Fraud Case and the district court's resentencing in the Theft Case. View "Snedeker v. People" on Justia Law

Roberto C. Silva-Jaquez was convicted in 2014 of two counts of first-degree murder, two counts of attempted first-degree murder, and one count of second-degree assault with a deadly weapon. His convictions were affirmed by the court of appeals. Silva-Jaquez then filed a pro se Crim. P. 35(c) motion for postconviction relief, claiming ineffective assistance of counsel. The postconviction court appointed alternate defense counsel, who supplemented the motion. Before the evidentiary hearing, the prosecution requested disclosures related to the defense's expert witness, which Silva-Jaquez opposed.The postconviction court granted the prosecution's request, relying on its inherent authority to manage cases, despite acknowledging that Crim. P. 16 did not apply to postconviction proceedings. The court believed it could order disclosures to avoid surprise and delay, referencing People v. Owens, which discussed inherent authority in managing dockets.The Supreme Court of Colorado reviewed the case and held that a trial court may not rely on its inherent authority to order discovery in a postconviction proceeding. The court emphasized that discovery in criminal cases must be authorized by a constitutional provision, statute, or rule. Since no such authority existed in this case, the court concluded that the postconviction court erred in ordering the disclosures. The Supreme Court made absolute the order to show cause and remanded the case for further proceedings consistent with its opinion. View "People v. Silva-Jaquez" on Justia Law

In the spring of 2020, Colorado State University (CSU) transitioned from in-person to online learning due to the COVID-19 pandemic. Renee Alderman and Tyler Stokes, both students, filed class action lawsuits seeking refunds for tuition and fees paid for that semester, alleging CSU breached its contract to provide in-person learning and access to facilities. They also claimed unjust enrichment. The district court dismissed the breach of contract claims, citing CSU's statutory authority to suspend operations during unforeseen calamities, and later dismissed the unjust enrichment claims, ruling that the contract covered the same subject matter.Alderman appealed, and the Colorado Court of Appeals reversed the district court's dismissal of her unjust enrichment claims, holding that CSU's invocation of the statute rendered the contract unenforceable, thus allowing the unjust enrichment claims to proceed.The Supreme Court of Colorado reviewed the case and concluded that the lower court erred in holding the contract unenforceable. The court held that the statutory provision allowing CSU to suspend operations was part of the contract, and the inability to state a breach of contract claim did not render the contract itself unenforceable. Consequently, Alderman's unjust enrichment claims failed as a matter of law because a valid, enforceable contract existed covering the same subject matter. The Supreme Court reversed the appellate court's decision and directed reinstatement of the district court's judgment in favor of CSU. View "Bd. of Governors of the Colo. State Univ. v. Alderman" on Justia Law

In 2023, the Board of County Commissioners of Weld County approved a new map for electing county commissioners without complying with Colorado's redistricting statutes, arguing that as a home rule county, it was exempt from these requirements. Weld County residents, along with the League of Women Voters of Greeley and the Latino Coalition of Weld County, sued the Board, seeking a declaratory judgment and an injunction to prevent the use of the new map.The Weld County District Court ruled in favor of the plaintiffs, granting summary judgment and enjoining the Board from using the new map. The court found that the plaintiffs had standing, the redistricting statutes applied to Weld County, and the Board had violated these statutes. The Board appealed to the Colorado Court of Appeals, and the plaintiffs petitioned the Colorado Supreme Court for certiorari review, which was granted.The Supreme Court of Colorado held that the redistricting statutes provide a private right of action and that the plaintiffs had standing to sue. The court further held that home rule counties must comply with the redistricting statutes, as these statutes impose mandatory functions rather than structural requirements. The court reversed the district court's allowance for the Board to use the 2015 map and ordered the Board to draw and approve a new map in compliance with the redistricting statutes in time for the 2026 county commissioner election. View "League of Women Voters of Greeley v. The Bd. of Cnty. Comm'rs of the Cnty. of Weld" on Justia Law

Independence Water and Sanitation District (Independence) sought to amend an augmentation plan to provide water services for a proposed residential development in Elbert County, Colorado. The original 2006 decree allowed Independence to withdraw groundwater from the Denver Basin and included an augmentation plan for not-nontributary groundwater from the Upper Dawson aquifer for specific uses on the property. Independence applied to amend this plan to include additional uses both on and off the property.The Division 1 water court faced opposition from Franktown Citizens Coalition II, Inc. and West Elbert County Well Users Association (Opposers), who argued that the anti-speculation doctrine should apply, requiring Independence to show a non-speculative intent to use the water. The water court denied Opposers' motion for summary judgment, agreeing with Independence that the anti-speculation doctrine did not apply to the amendment of the augmentation plan, based on the precedent set in East Cherry Creek Valley Water & Sanitation District v. Rangeview Metropolitan District.The Supreme Court of Colorado reviewed the case and affirmed the water court's decision. The court held that the anti-speculation doctrine does not apply to applications to amend augmentation plans for not-nontributary groundwater. The court reasoned that the anti-speculation doctrine and augmentation plans serve different purposes: the former prevents water hoarding within the prior appropriation system, while the latter allows out-of-priority diversions without injuring existing water rights. The court concluded that the sole inquiry for a water court reviewing an augmentation plan is whether the plan will cause injury to existing water rights, not the applicant's intent to use the water. The court found no clear error in the water court's determination that Independence's amended augmentation plan would not result in injury to existing water rights. View "Franktown Citizens Coal. II v. Indep. Water & Sanitation Dist." on Justia Law

Patrick Frazee was arrested in connection with the murder of his romantic partner, Kelsey Berreth. Following his arrest, the Teller County Department of Human Services took emergency custody of their daughter. Mary Longmire, a caseworker from the Department, met with Frazee in jail to discuss the child's welfare. During a subsequent meeting, Longmire asked Frazee questions about his background and relationship with Berreth, without providing Miranda warnings.The trial court denied Frazee's motion to suppress his statements to Longmire, ruling that Longmire was not a law enforcement officer or acting as an agent of law enforcement, and thus, Miranda warnings were not required. The court found that Longmire's actions were consistent with her duties under the Children's Code. The jury convicted Frazee of multiple charges, including first-degree murder.The Colorado Court of Appeals affirmed the trial court's decision, agreeing that Frazee was not in custody for Miranda purposes during his meeting with Longmire. Frazee then petitioned the Colorado Supreme Court for review.The Colorado Supreme Court affirmed the lower court's decision, concluding that Longmire was neither a law enforcement officer nor an agent of law enforcement. Therefore, Miranda warnings were not required. The court declined to adopt a bright-line rule that Miranda should apply to caseworkers conducting custodial interrogations involving criminal allegations. The court emphasized that Longmire's primary purpose was to assess the child's welfare, not to gather evidence for a criminal case. View "Frazee v. State" on Justia Law

In February 2017, Adam Douglas Densmore lived in Boulder with his child and the child's mother, Ashley Mead. After Mead went missing, Densmore was arrested in Oklahoma with the child. The Oklahoma Department of Human Services took custody of the child, and caseworker Jessica Punches interviewed Densmore at the jail without providing Miranda warnings. Punches's role was to ensure the child's safety and find appropriate placement, not to conduct criminal investigations.The trial court denied Densmore's motion to suppress his statements to Punches, finding that she was not acting as an agent of law enforcement. The court of appeals affirmed, applying a totality of the circumstances test and concluding that Punches's primary duties were related to child welfare, not law enforcement.The Supreme Court of Colorado reviewed the case to determine if Miranda v. Arizona applies when a Department of Human Services caseworker conducts a custodial interrogation. The court concluded that courts must consider the totality of the circumstances, including both objective and subjective factors, to determine if a caseworker acted as an agent of law enforcement. Applying this standard, the court found that Punches did not act as an agent of law enforcement and was not required to provide Miranda warnings. The court affirmed the judgment of the court of appeals. View "Densmore v. People" on Justia Law

Lakewood police agents followed Tien Dinh Pham after observing his vehicle leave a house in a high-crime area. They initiated a traffic stop for a lane change violation. Pham pulled into a parking lot, and the agents ordered him out of the vehicle. After a brief pat down, Pham was directed away from the car, leaving the door open. Agent Kyle Winters then deployed a drug-detection dog, which entered the vehicle and alerted to the presence of drugs. The agents searched the vehicle and found drugs, paraphernalia, and weapons. Pham was charged with multiple offenses, including possession with intent to distribute controlled substances and possession of a weapon by a previous offender.The Jefferson County District Court held a suppression hearing and ruled that the search was unconstitutional. The court found that the officers had no reason to remove Pham from his vehicle and acted improperly by leaving the door open, facilitating the dog's entry into the car. The court suppressed the evidence obtained from the search.The Supreme Court of Colorado reviewed the case. It concluded that the trial court erred in finding that removing Pham from his vehicle was improper, as officers may order a driver out of a vehicle during a lawful traffic stop for safety reasons. However, the court agreed that the dog's entry into the vehicle constituted a search under the Fourth Amendment. Since the search was conducted without probable cause, it was deemed unconstitutional. The Supreme Court of Colorado affirmed the trial court's suppression order and remanded the case for further proceedings. View "People v. Pham" on Justia Law

In 2015, Jesus Rodriguez-Morelos began offering Certified Nursing Assistant (CNA) classes, falsely claiming they were affiliated with the nonprofit organization United with Migrants. He charged students for these classes, which were not state-approved, and used the nonprofit's name and tax-exempt document without authorization. Complaints about the classes led to an investigation by the Colorado Department of Regulatory Agencies (DORA), revealing that Rodriguez-Morelos was unlawfully receiving money for the unapproved classes.Rodriguez-Morelos was charged with several crimes, including identity theft under section 18-5-902(1)(a), C.R.S. (2024). A jury convicted him on all charges. On appeal, the Colorado Court of Appeals affirmed the theft and criminal impersonation convictions but vacated the identity theft conviction. The court concluded that the identity theft statute's definition of "personal identifying information" pertains to individuals, not organizations, and thus did not apply to Rodriguez-Morelos's use of the nonprofit's name and document.The Supreme Court of Colorado reviewed the case and affirmed the Court of Appeals' decision. The court held that the identity theft statute's reference to "personal identifying information" applies only to information concerning single, identified human beings, not organizations. Therefore, Rodriguez-Morelos's actions did not constitute identity theft under the statute. View "People v. Rodriguez-Morelos" on Justia Law

Five elderly African elephants, Missy, Kimba, Lucky, LouLou, and Jambo, reside at the Cheyenne Mountain Zoo. The Nonhuman Rights Project, Inc. (NRP) filed a Verified Petition for Writ of Habeas Corpus on behalf of the elephants, seeking their transfer to a suitable elephant sanctuary. NRP argued that the elephants were unlawfully confined and had a right to bodily liberty due to their cognitive and social complexities. The petition included affidavits from animal biologists supporting the elephants' autonomy and complex needs.The El Paso County District Court dismissed the petition, ruling that Colorado's habeas corpus statute only applies to persons, not nonhuman animals. The court accepted NRP's allegations as true but concluded that the elephants lacked standing to seek habeas relief. The court also determined that NRP did not have proper next friend status to bring the petition on the elephants' behalf. Additionally, the court found that NRP failed to make a prima facie case that the elephants were unlawfully confined, as the zoo was operating within legal standards.The Supreme Court of Colorado reviewed the case and affirmed the district court's decision. The court held that the habeas corpus statute in Colorado applies only to persons, defined as human beings, and does not extend to nonhuman animals. The court rejected NRP's argument to rely on common law for broader habeas corpus rights, emphasizing that the statute explicitly limits relief to persons. The court also noted that recognizing nonhuman animals as persons would have significant legal and societal implications. Consequently, the elephants did not have standing to bring a habeas corpus claim, and the district court's dismissal was upheld. View "Nonhuman Rights Project, Inc. v. Cheyenne Mountain Zoological Soc'y" on Justia Law