Justia Colorado Supreme Court Opinion Summaries

David Samuel Crawford and A.L. ended their four-year relationship in 2018. Despite A.L.'s firm decision to end the relationship, Crawford persistently contacted, surveilled, and approached her for over four years. His actions included calling, emailing, texting, messaging on social media, contacting her friends and family, sending letters and gifts to her workplace, and showing up uninvited at her home. A.L. reported serious emotional distress due to Crawford's conduct, but law enforcement determined there was no imminent threat of harm as Crawford's actions did not include true threats.The Jefferson County District Court charged Crawford with two counts of stalking under section 18-3-602(1)(c), C.R.S. (2024). The prosecution sought to introduce evidence of Crawford's repeated contacts with A.L. Crawford challenged the charges, arguing they violated the First Amendment based on the precedent set in Counterman v. Colorado. The district court concluded that the prosecution needed to prove Crawford had recklessly disregarded that his repeated contacts would cause A.L. serious emotional distress.The Supreme Court of Colorado reviewed the case and held that stalking charges based on repeated actions, including contacts but not their contents, do not require proof of a reckless state of mind. The court reversed the district court's order expanding Counterman's holding and remanded the case for further proceedings. The court clarified that Counterman's recklessness mens rea requirement applies only to true-threats cases based on the content of speech, not to cases involving repeated, unwelcome, and content-neutral conduct. View "People v. Crawford" on Justia Law

Late one afternoon, Eugene Jennings was driving a tractor-trailer truck for his employer, All State Enterprise, Inc., in Custer County. As he negotiated a curve on Highway 69, his truck flipped over and crushed the vehicle in the oncoming lane driven by Timothy Trenshaw, killing him instantly. Jennings reported injuries and was transported to Parkview Hospital, where he discussed how he was injured with an emergency department physician. The physician documented these statements in Jennings's medical records.The district attorney's office for the Eleventh Judicial District charged Jennings with vehicular homicide and careless driving resulting in injury. Trenshaw's sister and son sued Jennings and All State in a wrongful death action. Plaintiffs obtained a police report containing a screenshot of Jennings's medical records, which included his description of the collision. Jennings filed a motion for a protective order, which the district court granted, prohibiting Plaintiffs from possessing or further disclosing Jennings's medical records. However, the district court later reviewed the screenshot in camera and ruled that five sentences describing the collision were not privileged, dissolving the protective order and requiring Jennings to disclose those sentences.The Supreme Court of Colorado reviewed the case and held that medical records containing information provided by a patient to a physician during treatment are protected by the physician-patient privilege. The court concluded that the district court erred in reviewing the screenshot and conducting a sentence-by-sentence analysis. The Supreme Court made absolute the order to show cause, emphasizing that the proper method for Plaintiffs to learn about the facts of the collision is through discovery directed at Jennings, not by accessing his privileged medical records. View "Gardne v. Jennings" on Justia Law

Patrick Nkongolo was charged with multiple counts of sexual assault on a child, A.K., as a pattern of abuse. A.K. disclosed to a therapist that Nkongolo had sexually assaulted her over three years, starting when she was eleven. The therapist reported this to Arapahoe County Human Services, which then informed the police. As part of the investigation, the police asked A.K.'s father, D.K., to initiate a text conversation with Nkongolo. During the conversation, guided by a police officer, D.K. asked Nkongolo about the allegations. Nkongolo downplayed the incidents but eventually apologized for upsetting A.K. and admitted to giving her a "friendly kiss."The Arapahoe County District Court reviewed the case and held a pretrial hearing. The court found that the statements made by Nkongolo on November 2 and 7 were voluntary and admissible. However, it concluded that the statements made on November 15 were involuntary due to implied promises by D.K. to keep the matter within the family if Nkongolo confessed. The court ruled that these implied promises were coercive and overbore Nkongolo's will, rendering his statements involuntary and inadmissible.The Supreme Court of Colorado reviewed the case and reversed the trial court's suppression of the November 15 statements. The Supreme Court concluded that D.K.'s conduct was not coercive and did not play a significant role in inducing Nkongolo's statements. The court held that Nkongolo's statements were voluntary and remanded the case for further proceedings. View "People v. Nkongolo" on Justia Law

The County Commissioners of Boulder County and the City of Boulder filed a lawsuit against Exxon Mobil Corporation and three Suncor Energy companies, alleging that the defendants' fossil fuel activities contributed to climate change, causing harm to Boulder’s property and residents. Boulder sought damages for public and private nuisance, trespass, unjust enrichment, and civil conspiracy, claiming that the defendants knowingly contributed to climate change while misleading the public about its impacts.The case was initially filed in Boulder County District Court but was removed to federal district court by the defendants. The federal district court remanded the case back to state court, and the Tenth Circuit affirmed this decision. The Boulder County District Court then denied the defendants' motion to dismiss, rejecting their arguments that Boulder's claims were preempted by federal law, including the Clean Air Act (CAA) and federal common law.The Supreme Court of Colorado reviewed the case and concluded that Boulder's claims were not preempted by federal law. The court held that the CAA displaced federal common law in this area, and thus, federal common law did not preempt Boulder's state law claims. The court also determined that the CAA did not preempt Boulder's claims under principles of express, field, or conflict preemption. Consequently, the court discharged the order to show cause and remanded the case to the district court for further proceedings, without expressing any opinion on the ultimate merits of Boulder's claims. View "Cnty. Comm'rs of Boulder Cnty. v. Suncor Energy U.S., Inc." on Justia Law

Patrick L. Beverly, II sold fentanyl pills to Matthew Bowen, who later died from consuming them. The coroner determined Bowen's death was a suicide. Beverly was charged with distributing less than four grams of fentanyl, with the distribution being the proximate cause of Bowen's death, which carries enhanced penalties under Colorado law.The El Paso County District Court denied the People's motion to exclude evidence of Bowen's suicidal intent, which Beverly intended to use as a defense. The People sought relief from the Supreme Court of Colorado, arguing that the trial court erred in its decision.The Supreme Court of Colorado held that evidence of a drug purchaser's suicidal intent might be relevant to determining whether the defendant's distribution of fentanyl was the proximate cause of the purchaser's death. The court reasoned that the term "proximate cause" includes the concept of an intervening cause, which can break the causal chain if the event is not reasonably foreseeable. The court concluded that a purchaser's suicide by intentional overdose could be an intervening cause, making the defendant's distribution not the proximate cause of death.The court also found that the trial court did not abuse its discretion in denying the People's motion to exclude evidence of Bowen's suicidal intent. The evidence was deemed relevant and not unduly prejudicial, as it could support Beverly's defense that Bowen's suicide was an intervening cause.The Supreme Court of Colorado discharged the order to show cause and affirmed the trial court's evidentiary ruling, allowing the evidence of Bowen's suicidal intent to be considered in determining proximate cause. View "People v. Beverly" on Justia Law

HIVE Construction, Inc. served as the general contractor for the construction of Masterpiece Kitchen, a restaurant. The contract required HIVE to follow specific architectural plans, including installing two layers of drywall on a wall separating the kitchen and dining area. Instead, HIVE installed one layer of drywall and one layer of combustible plywood without approval. A fire started within the wall, causing significant damage and forcing the restaurant to close. Mid-Century Insurance Company, as the property insurer and subrogee of Masterpiece Kitchen, paid for the damages and then sued HIVE for negligence, alleging willful and wanton conduct.The district court initially allowed Mid-Century to amend its complaint to include a breach of contract claim but later reversed this decision, requiring Mid-Century to proceed with the negligence claim. At trial, the jury found HIVE's conduct to be willful and wanton, awarding damages to Mid-Century. HIVE appealed, arguing that the economic loss rule barred the negligence claim. The Colorado Court of Appeals agreed, reversing the district court's decision and instructing a verdict in HIVE's favor.The Supreme Court of Colorado reviewed the case and concluded that the economic loss rule does not provide an exception for willful and wanton conduct. The court held that the rule barred Mid-Century's negligence claim because the duty HIVE allegedly breached was not independent of its contractual obligations. Consequently, the court affirmed the judgment of the Colorado Court of Appeals, upholding the application of the economic loss rule to bar the negligence claim. View "Mid-Century Ins. Co. v. HIVE Construction" on Justia Law

Late on the night of August 26, 2022, Arapahoe County Sheriff Deputy Swank heard gunshots while on patrol in Centennial, Colorado. He and other officers arrived at the scene near the Green Tree Hotel and found Sheron Mario Furness and his friend V.M. near a dark-colored Lexus sedan. Furness claimed to have seen a shooter and was looking for his car keys. Officers found the keys in a nearby grass-covered area and observed an empty gun case and an empty bottle of whiskey in the car. Furness was arrested for violating a protection order due to his admitted alcohol consumption. A witness identified Furness as the shooter, leading officers to search the vehicle, including the trunk, where they found a handgun, ammunition, drugs, and other items.The Arapahoe County District Court found that officers had probable cause to search the passenger compartment but not the trunk, as there was no access from the backseat to the trunk. The court suppressed the evidence found in the trunk, leading the People to file an interlocutory appeal.The Supreme Court of Colorado reviewed the case and concluded that the officers had probable cause to search the trunk based on the totality of the circumstances. The court noted that Furness was near the trunk when officers arrived, the car windows were down, and a witness identified Furness as the shooter. The court held that it was reasonable for officers to believe the trunk contained evidence of a crime. Consequently, the Supreme Court of Colorado reversed the district court's suppression order and remanded the case for further proceedings. View "People v. Furness" on Justia Law

J.D., a juvenile defendant, faced multiple charges and challenged his competency to proceed. The juvenile court ordered the Department of Human Services (the "Department") to conduct an in-custody competency evaluation, which found J.D. incompetent but restorable. The court then ordered outpatient restoration services. Subsequently, J.D. was charged with additional delinquent acts, and the court extended its incompetency finding to all cases, ordering the Department to oversee inpatient restoration services and provide periodic status reports.The Department later reassessed J.D.'s competency without a court order and concluded that he had been restored to competency. J.D. moved to strike the Department's report, arguing that the Department lacked the authority to conduct the evaluation without a court order under section 19-2.5-704(2)(c). The juvenile court denied the motion, finding that the Department had the authority to conduct restoration evaluations as part of its responsibility to provide restoration services.The Supreme Court of Colorado reviewed the case and held that the Department's responsibility to provide restoration services under section 19-2.5-704(2)(b) includes the authority to perform restoration evaluations without a court order. The court concluded that restoration evaluations are part of the "services necessary to competency restoration." Therefore, the juvenile court properly accepted and considered the Department's evaluation in finding J.D. restored to competency. The order to show cause was discharged. View "In re People ex rel. J.D." on Justia Law

Jina Garcia received treatment from St. Anthony North Hospital, operated by Centura Health Corporation, following a motor vehicle accident. Garcia informed the hospital that she had Medicare and Medicaid coverage and that her automobile insurance carrier was Progressive Insurance. Centura asserted a hospital lien against Garcia for $2,170.35 without billing Medicare first. Garcia filed a class action lawsuit against Centura, alleging violations of the hospital lien statute by filing liens before billing Medicare, seeking damages of twice the amount of the asserted liens.The District Court of the City and County of Denver certified a class and ordered Garcia to respond to substantial discovery requests from Centura. Garcia objected, arguing the requests were irrelevant, overbroad, and violated her privacy. The district court required Garcia to provide much of the requested discovery. Garcia sought relief from the Colorado Supreme Court, which issued an order to show cause and remanded the case for further proceedings, instructing the district court to determine the relevance and proportionality of the discovery requests.The Colorado Supreme Court reviewed the case again and concluded that the district court abused its discretion in ordering Garcia to respond to the discovery requests. The court found that the discovery sought by Centura was not relevant to the claims or defenses in the case and was not proportional to the needs of the case. The court emphasized that the principal factual issues were whether Centura asserted liens without billing Medicare and the amount of those liens. The court made its order to show cause absolute and remanded the case to the district court for further proceedings consistent with its opinion. View "Garcia v. Centura Health Corp." on Justia Law

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