Justia Colorado Supreme Court Opinion Summaries

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

Rachel Ann Niemeyer was questioned by police after her husband suffered a gunshot wound to the head. During the interrogation at the police station, Niemeyer made incriminating statements. She was charged with murdering her husband and moved to suppress these statements, arguing they were obtained in violation of Miranda v. Arizona. The trial court denied her motion, concluding she was not in custody when she made the statements. A jury convicted her of second-degree murder and other offenses.The Colorado Court of Appeals affirmed the trial court's decision. The majority held that a reasonable person in Niemeyer's position would not have considered herself in custody, as her freedom of action was not curtailed to the degree associated with a formal arrest. The court reasoned that the hand-bagging procedure did not convert the situation into a custodial one. However, a dissenting judge argued that the police's actions and statements indicated that Niemeyer was in custody, as they would not consider taking her to the hospital until completing unspecified tasks.The Supreme Court of Colorado reviewed the case and held that Niemeyer was in custody for Miranda purposes during the interrogation. The court found that a reasonable person in her position would have believed they were deprived of their freedom of action to a degree associated with a formal arrest. The court noted that Niemeyer was alone in an interrogation room late at night, repeatedly asked to go to the hospital, and was physically restrained with zip-tied bags on her hands. The court concluded that the trial court's error in admitting her statements was not harmless and reversed the judgment of the court of appeals, remanding for further proceedings. View "Niemeyer v. People" on Justia Law

Police officers questioned Terrence Kenneth Eugene about his involvement in a road-rage incident without informing him of his Miranda rights. During the encounter, Eugene admitted to pushing the other driver but denied using a weapon. His statements were used at trial, leading to his conviction for second and third-degree assault.The trial court denied Eugene's motion to suppress his statements, finding he was not in custody for Miranda purposes. The court noted that Eugene's movement was not restricted, the officers did not use coercive tactics, and Eugene was not formally arrested. A jury subsequently convicted Eugene.On appeal, the Colorado Court of Appeals reversed the convictions, concluding that Eugene was in custody during the interrogation and that the trial court erred in not suppressing his statements. The appellate court found that the circumstances of the interrogation, including the officers' tone and the duration of the encounter, indicated a custodial situation.The Supreme Court of Colorado reviewed the case and reversed the appellate court's decision. The court held that Eugene was not in custody for Miranda purposes, emphasizing the public and non-coercive nature of the encounter. The court noted that Eugene was questioned outside his apartment in broad daylight, was not physically restrained, and the officers did not use force or threats. Consequently, the court reinstated the trial court's suppression ruling and remanded the case to the court of appeals for further proceedings. View "People v. Eugene" on Justia Law

The defendant, Phillip Romero, was charged with multiple offenses, including assault and false imprisonment, after threatening and attacking his romantic partner. During jury selection, the prosecution used a peremptory strike to excuse Prospective Juror F, one of two Hispanic jurors in the pool. Romero raised a Batson challenge, arguing that the strike was racially motivated. The prosecution explained that the juror appeared disinterested and unfocused. The trial court denied the Batson challenge, finding the prosecution's reason credible and race-neutral.The Colorado Court of Appeals reviewed the case and reversed the trial court's decision, concluding that the trial court had clearly erred in denying the Batson challenge. The appellate court held that the prosecution's reason lacked specific factual justification and objective evidence, and thus, the trial court should not have credited it. The appellate court ordered a new trial for Romero.The Supreme Court of Colorado reviewed the appellate court's decision. The Supreme Court held that the appellate court misapplied the clear error standard of review by not deferring to the trial court's credibility determinations. The Supreme Court emphasized that the trial court is in the best position to assess demeanor and credibility. It found that the trial court had implicitly found the prosecution's reason credible and that the record supported this finding. The Supreme Court reversed the appellate court's decision and remanded the case for consideration of other issues raised by Romero on appeal. View "People v. Romero" on Justia Law

Richard Lewis was convicted of four misdemeanors, including two counts of unlawful sexual contact and two counts of unlawful sexual contact on a client by a psychotherapist. Initially, he was on a personal recognizance bond, but after his conviction, the county court revoked this bond, citing the seriousness of the case and Lewis's potential danger to the community. The court set a new cash bond of $5,000, which Lewis posted. At sentencing, the court denied Lewis's request for an appeal bond, finding that he posed a danger to the community.The County Court, City and County of Denver, denied Lewis's request for an appeal bond under section 16-4-201.5(2)(a), which requires denial of bail if the defendant poses a danger to the community. Lewis argued that his appeal should be governed by section 16-2-114(6), which mandates a stay of execution and an appeal bond. The county court disagreed, finding that Lewis posed a danger to the community and thus denied the appeal bond.The Supreme Court of Colorado reviewed the case and upheld the county court's decision. The court clarified that section 16-2-114(6) requires a stay of execution but does not mandate the granting of an appeal bond. The court found no conflict between section 16-2-114(6) and section 16-4-201.5(2), which prohibits bail if the defendant is deemed a danger to the community. The Supreme Court concluded that the county court did not abuse its discretion in denying the appeal bond and discharged the order to show cause. The case was remanded to the county court for further proceedings consistent with this opinion. View "People v. Lewis" on Justia Law