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 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

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

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

The petitioners, including The Gazette and the Invisible Institute, sought records from the Colorado Peace Officer Standards and Training Board (POST) regarding peace officer demographics, certification, and decertification. They argued that these records should be disclosed under the Colorado Open Records Act (CORA). POST countered that the records were criminal justice records governed by the Colorado Criminal Justice Records Act (CCJRA), which allows the custodian discretion in disclosing records.The Denver District Court agreed with POST, concluding that POST is a criminal justice agency under the CCJRA and that the requested records were criminal justice records. The court found that POST's activities, such as conducting criminal background checks and investigating officers, qualified it as a criminal justice agency. The court held that the custodian did not abuse her discretion in partially denying the records requests due to concerns about officer safety and ongoing investigations.The Colorado Court of Appeals affirmed the district court's decision, albeit on slightly different grounds. The appellate court concluded that POST is a criminal justice agency because it collects and stores arrest and criminal records information when it revokes a peace officer's certification.The Supreme Court of Colorado reviewed the case and affirmed the judgment of the court of appeals. The court held that POST qualifies as a criminal justice agency because it performs activities directly related to the detection or investigation of crime. This includes conducting criminal investigations into officers and applicants suspected of criminal offenses. Consequently, the CCJRA governs the records requested by the petitioners, allowing the custodian discretion in their disclosure. View "The Gazette v. Bourgerie" on Justia Law

In 1996, Rodney Dewayne McDonald was convicted by a jury of attempted first-degree murder, second-degree assault, possession of a weapon by a previous offender, and two habitual criminal counts. The habitual criminal counts were based on prior felony convictions from 1994 and 1995. McDonald was sentenced to seventy-two years in prison, and his conviction became final in 1999.In 2007, McDonald sought a proportionality review of his sentence, which the district court denied, concluding that the sentence was not grossly disproportionate. The Colorado Court of Appeals affirmed this decision. Following the 2019 Wells-Yates decision, which altered the proportionality-review process in Colorado, McDonald moved for a second proportionality review, arguing that his sentence was unconstitutional under the new rules. The district court denied this motion, stating that Wells-Yates had not been applied retroactively by higher courts. The Colorado Court of Appeals upheld this decision, agreeing that Wells-Yates did not apply retroactively.The Supreme Court of Colorado reviewed the case and concluded that the Wells-Yates decision did not announce new substantive rules of constitutional law and therefore did not apply retroactively to cases on collateral review. The court held that Wells-Yates merely clarified existing law and did not change the substantive reach of the habitual criminal statute. Consequently, McDonald was not entitled to a second proportionality review of his sentence. The judgment of the Colorado Court of Appeals was affirmed. View "McDonald v. State" on Justia Law

In 1993, David L. Ward was convicted by a jury of robbery, aggravated robbery, and three habitual criminal counts based on prior felony convictions. The trial court sentenced him to life imprisonment. Ward appealed, and the Colorado Court of Appeals affirmed his robbery and aggravated robbery convictions but remanded the case to determine if Ward had a justifiable excuse for his untimely challenge to the prior convictions. The trial court found no justifiable excuse, and the appellate court affirmed the habitual criminal counts. Ward's convictions became final in 1999.In 2020, Ward filed a pro se motion for a proportionality review of his sentence under the Wells-Yates decision. The postconviction court concluded that Ward's claims were time-barred under Colorado law. On appeal, the Colorado Court of Appeals held that Wells-Yates did not create a new substantive constitutional rule that applies retroactively and affirmed that Ward's collateral attack was untimely.The Supreme Court of Colorado reviewed the case and applied its conclusion from a companion case, McDonald v. People, that Wells-Yates's holdings do not apply retroactively to cases on collateral review. The court found that Ward did not establish justifiable excuse or excusable neglect for failing to collaterally attack his prior convictions within the required three-year period. Consequently, the court concluded that Ward's collateral attack was untimely and affirmed the judgment of the Colorado Court of Appeals. View "Ward v. State" 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