Justia Colorado Supreme Court Opinion Summaries

Petitioner Joe Anthony Martinez was convicted by jury for first-degree murder after deliberation under a complicity theory. When the court instructed the jury on "after deliberation," it used language that the Supreme Court had previously held as constitutionally deficient. At trial, defense counsel objected to the language on grounds that it was cumulative and unnecessary, but erroneously acknowledged that it correctly stated the law. The trial court overruled the objection and the jury found defendant guilty as charged. On appeal, petitioner raised for the first time the argument that the Supreme Court previously disapproved the definition of "after deliberation" used in the jury instructions, and that the erroneous instruction was so prejudicial as to require reversal as plain error. He also renewed claims that the evidence presented against him was insufficient to sustain his conviction. The court of appeals reviewed the instruction for plain error and ultimately upheld petitioner's conviction. Finding no reversible error in the court of appeal's judgment, the Supreme Court also affirmed. View "Martinez v. Colorado" on Justia Law

The Department of Corrections directly appealed to the Supreme Court the grant of habeas relief to petitioner-appellee Randal Ankeney. Complying with a mandate from the court of appeals (in an earlier appeal), the district court interpreted various statutory provisions regarding good time and earned time credit to require Ankeney's release from prison almost three years before the date calculated by the Department. Because the lower courts erred in their conclusions that for inmates convicted after July 1, 1993, good time credits awarded pursuant to C.R.S. 17-22.5-301 (2014), were to be applied against an inmate's mandatory release date rather than to determine his parole eligibility. The Supreme Court concluded that had the credits been properly applied, Ankeney had not completed service of his required parole term. Therefore, the Supreme Court reversed the district court's order. View "Ankeney v. Raemisch" on Justia Law

In an interlocutory appeal, the State appealed a trial court order to suppress certain statements made by defendant Luis Carrion during a custodial interrogation. Officers gave Carrion an oral Miranda advisement and provided him an English language written advisement on a waiver form, which he later signed. After finding the oral Miranda advisement deficient and that the prosecution presented insufficient evidence Carrion was able to read English, the trial court suppressed the statements made during the interrogation. The prosecution argued that the trial court erred because the factual findings were not supported by the record. Upon review, the Colorado Supreme Court concluded that the trial court's factual findings were indeed supported by the record and were not clearly erroneous. Therefore, the Court affirmed the trial court's order. View "Colorado v. Carrion" on Justia Law

Petitioner Eric Doyle appealed the court of appeals' decision to affirm his conviction for violating a condition of his bail bond. At the request of the prosecution, the trial court took judicial notice of the fact that petitioner failed to appear in court on a particular day, as mandated by the bond. Upon review, the Supreme Court found, however, that the trial court had not instructed the jury that the judicially noticed fact was not subject to reasonable dispute and had already been accepted as true by the court. The Court found this error was not harmless, notwithstanding proper admission into evidence of a court record reflecting the court's earlier finding to that effect. The judgment of the court of appeals was reversed, and the case remanded to the trial court for a new trial. View "Doyle v. Colorado" on Justia Law

In an interlocutory appeal, the State sought the Supreme Court's review of a trial court order suppressing marijuana that police discovered in a car registered to and driven by defendant-appellee Ramiro Munoz-Gutierrez. The trial court found that the State did not establish that defendant voluntarily consented to the search of his car. After review, the Supreme Court found that the trial court applied the wrong legal standard, and held that defendant indeed voluntarily consented to the search. Under the totality of the circumstances, the police's conduct did not overbear defendant's exercise of free will. Accordingly, the Court reversed the trial court's suppression order and remanded the case for further proceedings. View "Colorado v. Munoz-Gutierrez" on Justia Law

This case stemmed from a series of contracts surrounding the construction of a custom home. Petitioners are soil engineering corporations that subcontracted with developer Sun Mountain Enterprises, LLC to perform soil analysis and soil engineering related to the construction of the home. SK Peightal Engineers, LTD entered an oral contract with general contractor Shannon Custom Homes. Petitioner Hepworth-Pawlak Geotechnical, Inc. entered into a written contract with Sun Mountain containing a duty of care provision. It was unclear whether SK Peightal's oral contact contained the same duty of care requirement. Sun Mountain planned on selling the completed home on the open market, but due to the economic downturn, the house sat until the construction loan contract matured and came due, at which point Sun Mountain and its lender entered into an "Agreement for Deed-in-Lieu of Foreclosure. Sun Mountain was thereby absolved of personal liability for the loan, and the bank took ownership of the house. After the lender took possession, large cracks formed in the walls of the home due to a settling of the soil beneath the home's foundation. The lender sued petitioner soils engineers for negligence. Petitioners moved for summary judgment under the economic loss rule, asserting that the lender was contractually interrelated through the deed-in-lieu and the loan contract to the duty provisions contained in petitioners' contracts with Sun Mountain, and thus the lender was barred from asserting a negligence claim for economic loss. The trial court rejected petitioners' motion. Petitioners then appealed. After review, the Colorado Supreme Court reversed and remanded, finding the appellate court misinterpreted the case law authority pertaining to this case. View "S K Peightal Engineers, LTD v. Mid Valley Real Estate Solutions V" on Justia Law

Defendant Michael Blagg was convicted by jury of first degree murder for the death of his wife, for which he received a life sentence without parole. Years later, the trial court granted Blagg a new trial based on revelations of juror misconduct. After setting a new bond hearing, but before that hearing occurred, the court reinstated the bod amount it had set before Blagg's first trial. Because the trial court dispensed with the hearing, neither party had the change to argue changed circumstances and the alleged victim's family did not have the opportunity to be heard. The district attorney argued that this violated the Victims' Rights Act (VRA), and moved for an emergency stay of the trial court's order. The trial court denied the motion, and the district attorney petitioned the Supreme Court for certiorari. Upon review, the Colorado Supreme Court found that the trial court erred in dispensing the hearing, which was indeed, in violation of the VRA. View "Colorado v. Blagg" on Justia Law

The issue this case presented for the Supreme Court's review centered on whether the Special District Act (SDA) gave special districts the power to assign to a private party the right to receive development fees. Cherry Creek South Metropolitan District 1 assigned to a predecessor-in-interest of petitioner SDI, Inc. the right to receive fees the District assessed on developers within its boundaries to finance development of municipal infrastructure. The District increased the fees by about four percent each of the years prior to the assignment. SDI increased the fees it collected, but at a rate of eight percent per year. SDI sued Pivotal Parker Commercial, LLC to recover unpaid development fees, and requested a declaratory judgment that it could raise annual fees in the future. The trial court held that SDI was entitled to receive the fees as increased annually. Pivotal argued on appeal that the fee increase was an improper delegation of legislative authority. The appellate court reversed the trial court, which found that the District had no right to assign the fees. The Supreme Court reversed the court of appeals, finding that the appellate court's reasoning was contrary to the SDA itself. As such, the Supreme Court held that the District's assignment of the right to collect fees was a lawful exercise of its statutory authority. The case was remanded to the appellate court for consideration of other issues Pivotal raised on appeal. View "SDI, Inc. v. Pivotal Parker, LLC" on Justia Law

In a case brought under the Colorado Supreme Court's origination jurisdiction, the issue presented centered on whether a default judgment could be set aside as void for lack of jurisdiction due to the existence of a contractual forum selection clause. The clause at issue here purported to divest Colorado courts of jurisdiction over the dispute. After the trial court set aside the default judgment, plaintiff Christopher Nickerson sought to have the default reinstated against defendant Network Solutions, LLC. and Web.com Group, Inc. Upon review, the Supreme Court concluded the trial court erred in setting aside the judgment "A forum selection clause . . . does not divest a court of jurisdiction but instead presents the question of whether it is reasonable for the trial court to exercise its jurisdiction in the particular circumstances of the case. Therefore, the Supreme Court concluded the default judgment was not void; the trial court was directed to reinstate the default judgment in favor of plaintiff. View "In re Nickerson v. Network Solutions, LLC" on Justia Law

In 1952, Congress passed a resolution establishing a "National Day of Prayer," which was later officially defined as the first Thursday of May. Colorado's governor has issued annual honorary proclamations recognizing a Colorado Day of Prayer since 2004. In the past, a public event has been held on the steps of the Colorado Capitol to celebrate the Colorado Day of Prayer. The State Supreme Court granted certiorari to determine whether Respondents Freedom from Religion Foundation and four of its Colorado members had standing to sue Petitioner Governor John Hickenlooper in his official capacity for issuing annual honorary proclamations that recognize a "Colorado Day of Prayer." Contrary to the holding from the court of appeals, the Supreme Court held that the use of public funds to cover the incidental overhead costs associated with issuing the honorary proclamations does not, by itself, constitute an injury sufficient to establish taxpayer standing. Furthermore, contrary to the trial court, the Supreme Court held that the psychic harm endured by Respondents as a result of media coverage revealing the existence of the honorary proclamations did not, by itself, constitute an injury sufficient to establish individual standing. Accordingly, the court of appeals' judgment was reversed, and the case remanded with instructions to return the case to the trial court for dismissal. View "Hickenlooper v. Freedom from Religion Foundation, Inc." on Justia Law