Justia Colorado Supreme Court Opinion Summaries

Parker Water and Sanitation District, a Colorado special district, applied for six permits to construct wells to withdraw nontributary groundwater from the Denver Basin aquifers. The State Engineer approved the applications and issued the permits, including an allowed average annual withdrawal rate and, for the first time, an explicit condition limiting the total volume of groundwater that could be withdrawn over the life of the permits. Parker challenged this condition, arguing that the State Engineer lacked the authority to impose such a limit.The Water Division One court found in favor of the State Engineer, concluding that section 37-90-137, C.R.S. (2024), and the Statewide Nontributary Ground Water Rules unambiguously set forth a total volumetric limit on the amount of nontributary Denver Basin groundwater a permittee may withdraw. The court determined that the statute and rules require a total volumetric limit equal to the quantity of nontributary groundwater underlying the land owned by the applicant, as determined by the State Engineer at the time the well permit is issued.The Supreme Court of Colorado affirmed the water court's decision, holding that section 37-90-137 unambiguously imposes a total volumetric limit on nontributary groundwater withdrawals over the lifetime of a well permit. The court also held that this limit applies to well permits issued under both the current statute and the earlier version enacted through Senate Bill 213. Additionally, the court concluded that the Statewide Nontributary Ground Water Rules unambiguously impose a total volumetric limit and that the State Engineer has the authority to include such a limit in well permits. The court further held that water court decrees determining use rights for nontributary Denver Basin groundwater set forth a total volumetric limit on withdrawals unless an underlying decree explicitly provides otherwise. Finally, the court found that the water court did not abuse its discretion in staying discovery. View "Parker Water & Sanitation Dist. v. Rein" on Justia Law

Francine Erica Segura was involved in an armed home invasion robbery and was subsequently charged and convicted of multiple crimes, including second-degree kidnapping and aggravated robbery. She was sentenced to 111 years in prison, which was later reduced to 73 years upon her request for sentence reconsideration. Segura then filed a pro se motion under Colorado Rule of Criminal Procedure 35(c), claiming ineffective assistance of trial counsel and requesting postconviction counsel.The trial court reviewed Segura's motion and denied ten out of eleven claims, forwarding the remaining claim to the prosecution and the Office of the Public Defender (OPD). Due to a conflict of interest, an attorney from the Office of Alternate Defense Counsel (OADC) was appointed. This attorney filed a supplemental motion focusing on the single surviving claim, which was ultimately denied after an evidentiary hearing. Segura appealed, and the Colorado Court of Appeals reversed the trial court's decision in part, ruling that the trial court had improperly restricted the scope of postconviction counsel's representation.The Supreme Court of Colorado reviewed the case and held that under Rule 35(c)(3)(IV)-(V), a trial court must either deny all claims in a pro se motion or forward the entire motion to the OPD if any claim has arguable merit. The court rejected the prosecution's argument for a hybrid approach that would allow partial denial of claims. The Supreme Court affirmed the Court of Appeals' decision, ruling that the trial court violated the procedural requirements of Rule 35(c)(3)(IV)-(V) by limiting the scope of postconviction counsel's representation. The case was remanded for further proceedings consistent with this opinion. View "People v. Segura" on Justia Law

Pete Paul Martinez was charged with first-degree murder and pleaded not guilty by reason of insanity (NGRI). Dr. Charles Harrison, a psychologist at the Colorado Mental Health Institute, conducted a sanity evaluation and concluded that Martinez was legally sane at the time of the offense. The prosecution did not initially list Dr. Harrison as an expert witness but later included him in a supplemental witness list without formally designating him as an expert. During the trial, Dr. Harrison testified about Martinez's mental state without being formally tendered and accepted as an expert witness.The trial court admitted Dr. Harrison's testimony, and Martinez was convicted. On appeal, a division of the Colorado Court of Appeals reversed the conviction, ruling that Dr. Harrison's testimony was inadmissible because he was not formally offered and accepted as an expert witness. The majority held that his testimony exceeded the scope of lay testimony under Colorado Rule of Evidence (CRE) 701. Judge Tow dissented, arguing that Martinez had waived any objection and that any error was not plain.The Supreme Court of Colorado reviewed the case and concluded that CRE 702 and relevant case law do not require a formal offer and acceptance of an expert witness for their testimony to be admissible. The court held that as long as the expert testimony meets the requirements of CRE 702 and the standards set in People v. Shreck, the lack of formal tender and acceptance does not render the testimony inadmissible. The court found that the trial court did not err in admitting Dr. Harrison's testimony and reversed the appellate court's decision, remanding the case for further proceedings on unresolved issues. View "People v. Martinez" on Justia Law

Naomi Bermudez, a tenant in a federally subsidized housing complex managed by Mercy Housing Management Group Inc., faced eviction after Mercy Housing alleged she violated her lease by having an unauthorized guest who stayed beyond the allowed period, repaired vehicles on the property, and harassed another resident. Bermudez denied these allegations and requested a jury trial to resolve the factual disputes.The Denver County Court denied Bermudez's request for a jury trial, stating that there is no constitutional right to a jury trial in civil matters in Colorado. Bermudez then filed a petition with the Supreme Court of Colorado, arguing that she was entitled to a jury trial under the Colorado Rules of Civil Procedure and the statutory framework governing forcible entry and detainer (FED) actions.The Supreme Court of Colorado reviewed the case and held that Bermudez is entitled to a jury trial on the factual disputes in the FED-possession action. The court found that the right to a jury trial in such cases is rooted in the statutory framework and the Colorado Rules of Civil Procedure, specifically C.R.C.P. 338(a), which provides for a jury trial in actions for the recovery of specific real property. The court also determined that the FED statute and C.R.C.P. 338(a) are compatible and that the statutory right to a jury trial applies to factual disputes in FED-possession actions.The court acknowledged concerns about the potential burden on the county courts but concluded that the limited nature of the jury-trial right would not prove unworkable. The court reversed the county court's denial of Bermudez's jury demand, made absolute the order to show cause, and remanded the case with instructions for the county court to schedule a jury trial on the factual issues related to the possession dispute. View "Mercy Housing Management Group Inc. v. Bermudez" on Justia Law

Autumn Scardina requested a cake from Masterpiece Cakeshop to celebrate her gender transition. The shop, owned by Jack Phillips, refused to make the cake, citing the message as the reason. Scardina filed a discrimination claim with the Colorado Civil Rights Division, which found probable cause of discrimination. The Colorado Civil Rights Commission took jurisdiction but later dismissed the case as part of a confidential settlement in a federal lawsuit filed by Phillips, without Scardina's participation.The district court took up Scardina's case after the Commission's dismissal and found that Phillips had violated Colorado's Anti-Discrimination Act (CADA), imposing a fine. The Colorado Court of Appeals affirmed this decision. Phillips then appealed to the Supreme Court of Colorado.The Supreme Court of Colorado held that the district court should not have heard Scardina's case. The court concluded that Scardina did not exhaust her administrative remedies as required by CADA. Specifically, the court found that Scardina should have appealed the Commission's decision to close the administrative adjudication without issuing the required order. The court vacated the lower courts' decisions and dismissed the case, stating that the district court lacked jurisdiction to hear the matter. View "In re Masterpiece Cakeshop, Inc." on Justia Law

In October 2018, the petitioner and several friends planned to rob alleged drug dealers at gunpoint. During one of these planned robberies, the petitioner and his group approached a victim, K.H., and during the confrontation, the petitioner and another individual fired their weapons, resulting in K.H.'s death. The petitioner was subsequently arrested and charged with multiple offenses, including first-degree felony murder and aggravated robbery.The case proceeded to trial in the El Paso County District Court, where a jury convicted the petitioner on most counts, including felony murder. The trial court sentenced him to life without the possibility of parole (LWOP) for the felony murder conviction, plus additional years for other charges. The petitioner appealed, arguing that his LWOP sentence for felony murder was unconstitutional under the Eighth Amendment. The Colorado Court of Appeals affirmed the conviction and sentence, concluding that the LWOP sentence was not categorically unconstitutional and was proportionate to the offense.The Supreme Court of Colorado reviewed the case and held that an LWOP sentence for felony murder for an adult offender is not categorically unconstitutional. The court reasoned that there was no national consensus against such sentences and that the sentence served legitimate penological goals such as retribution, deterrence, and incapacitation. The court also conducted an abbreviated proportionality review and concluded that the petitioner's offense was grave and serious, and thus, the LWOP sentence was not grossly disproportionate. Consequently, the court affirmed the judgment of the Colorado Court of Appeals. View "Wayne Tc Sellers IV v. People" on Justia Law

Kevin Klabon, a technician for CMI Legacy, LLC, was injured in a car accident while driving a company van. The accident was caused by Rodrigo Canchola-Rodriguez, an underinsured driver. Klabon received workers' compensation benefits from CMI's carrier, Pinnacol Assurance, and settled with Canchola-Rodriguez's insurer for $25,000. He then sought additional underinsured motorist (UIM) benefits from CMI's commercial auto insurer, Travelers Property Casualty Company of America, which valued his claim at $78,766 but paid only $45,766.68.Klabon sued Travelers in state court for unreasonable denial and delay of UIM benefits, alleging bad faith and breach of contract. Travelers removed the case to federal court and moved for summary judgment, arguing that Klabon's receipt of workers' compensation benefits barred his UIM claim under Colorado's Workers' Compensation Act (WCA). The United States Magistrate Judge certified the question to the Colorado Supreme Court, given conflicting precedents and significant public policy implications.The Colorado Supreme Court concluded that an employee injured by a third-party tortfeasor and who receives workers' compensation benefits is not barred from suing their employer's UIM insurer. The court held that the WCA's exclusivity provisions immunize only employers and their workers' compensation carriers, not separate UIM insurers. The court also determined that a suit to recover UIM benefits does not constitute a suit against the employer or co-employee and thus is not barred by the WCA. The court answered the certified question in the negative, allowing Klabon to pursue his claim against Travelers. View "Klabon v. Travelers Property Casualty Company of America" on Justia Law

The case involves Ashton Michael Whittington, who was accused of providing alcohol to a minor and being complicit in her sexual assault on May 14, 2023. Formal charges were filed against him on December 27, 2023. Under Colorado Rule of Criminal Procedure 16(I)(b)(1), the prosecution was required to disclose certain evidence within twenty-one days of filing charges, but they failed to do so within the required timeframe. Subsequent disclosures were made in February and March 2024, some of which contained broken links, leading to communication issues between the defense and prosecution.The Ouray County Court partially granted Whittington's motion for sanctions against the Seventh Judicial District Attorney's Office for these discovery violations. Whittington requested dismissal of the charges, but the court instead excluded all evidence disclosed after the January 17, 2024 deadline from the preliminary hearing. The court did not make specific findings to justify this exclusion, such as willful misconduct or a pattern of violations by the prosecution. The People appealed the sanction order to the district court, which dismissed the appeal, suggesting the matter should be taken up as an original proceeding.The Supreme Court of Colorado reviewed the case and concluded that the Ouray County Court abused its discretion by excluding evidence without making the necessary findings to justify such a severe sanction. The Supreme Court emphasized that exclusion of evidence is a drastic remedy and should be supported by findings of willful misconduct or a pattern of neglect. The court reversed the county court's order imposing sanctions and remanded the case for further proceedings. View "People v. Whittington" on Justia Law

Lazy D Grazing Association manages a 25,000-acre ranch along the Colorado-Wyoming border, which lacks sufficient surface water for irrigation. In 2020, Lazy D sought a determination from the water court that the groundwater beneath the ranch in the Upper Laramie Aquifer is nontributary, meaning it is not subject to Colorado's prior appropriation system. This designation would allow Lazy D to control the use of the groundwater. The State Engineer determined that the groundwater was nontributary, prompting opposition from various entities, including the Cities of Sterling and Fort Collins, who feared it would harm their water rights.The District Court for Water Division 1 in Greeley found in favor of Lazy D, determining that the groundwater was nontributary. The Cities of Sterling and Fort Collins appealed, arguing that the State Engineer exceeded his authority, the water court improperly presumed the truth of the State Engineer's findings, and that the court relied on sources not in evidence while discrediting expert testimony without justification.The Supreme Court of Colorado reviewed the case and affirmed the water court's decision. The court held that the State Engineer was within his rights to determine the facts regarding whether the groundwater is nontributary, but the final determination is a mixed question of fact and law for the water court. Although the water court erred in giving a presumption of truth to the State Engineer's legal conclusion, this error was deemed harmless as the water court independently concluded that the groundwater was nontributary. The court also found that the water court did not improperly shift the burden of proof to the Cities and did not rely on information outside the record. The water court's reliance on expert testimony was found to be appropriate, and the decision to allow Lazy D to use the nontributary groundwater was upheld. View "City of Sterling v. Lazy D Grazing Association" on Justia Law

Dan Hamilton, an employee at an Amazon warehouse in Aurora, Colorado, received both holiday pay and holiday incentive pay. Holiday pay was his regular hourly rate for company holidays, regardless of whether he worked. Holiday incentive pay was one and one-half times his regular rate for hours worked on holidays. Hamilton filed a class action complaint alleging Amazon violated the Colorado Wage Act by not including holiday incentive pay in the calculation of his overtime pay.The case was initially filed in Arapahoe County District Court but was removed to the United States District Court for the District of Colorado. Amazon moved to dismiss the complaint, arguing that holiday incentive pay could be excluded from the regular rate of pay under both Colorado law and the Federal Fair Labor Standards Act (FLSA). The federal district court agreed with Amazon, ruling that Colorado law did not require the inclusion of holiday incentive pay in the regular rate of pay calculation, and dismissed Hamilton's complaint. Hamilton appealed to the Tenth Circuit, which then certified a question of law to the Supreme Court of Colorado.The Supreme Court of Colorado reviewed the certified question and concluded that holiday incentive pay must be included in the calculation of the regular rate of pay under Colorado law. The court found that the plain language of the relevant regulations, specifically 7 Colo. Code Regs. § 1103-1:1.8 and 1.8.1, mandated the inclusion of all compensation for hours worked, including holiday incentive pay. The court rejected Amazon's arguments that holiday incentive pay could be excluded and that Colorado law should be interpreted in line with the FLSA. The court held that holiday incentive pay is a form of shift differential and must be included in the regular rate of pay calculation. View "Hamilton v. Amazon.com Services" on Justia Law