Justia Colorado Supreme Court Opinion Summaries

The police were conducting an operation to arrest Anthony Veloz at a motel when they encountered Oscar Jonas Ganaway walking toward the motel. An officer asked Ganaway where he was going, and Ganaway pointed to Veloz's room. A detective then asked Ganaway if he could pat him down for weapons, and Ganaway consented. During the patdown, the detective found methamphetamine and arrested Ganaway. Ganaway moved to suppress the evidence, arguing that the initial encounter was a seizure and the evidence should be suppressed.The Arapahoe County District Court granted Ganaway's motion to suppress, finding that the initial encounter was a seizure and that the officers lacked reasonable suspicion. The court concluded that the evidence obtained from the search must be suppressed. The People appealed the trial court's order.The Supreme Court of Colorado reviewed the case and held that the initial encounter between the police and Ganaway was not a seizure, meaning it did not trigger Fourth Amendment protections. The court further held that Ganaway voluntarily consented to the patdown. Consequently, the Supreme Court of Colorado reversed the trial court's suppression order and remanded the case for further proceedings consistent with its opinion. View "People v. Ganaway" on Justia Law

The case involves a dispute between a railroad company and La Plata County over land use changes made by the railroad at its Rockwood Station. The railroad made several modifications to accommodate increased passenger traffic, including enlarging a parking lot and adding portable toilets and tents. The County claimed these changes violated its land use code and demanded compliance or corrective action.The railroad initially sought a declaratory judgment and an injunction in La Plata County District Court, arguing that the County lacked jurisdiction over its operations. While this case was pending, the County petitioned the Colorado Public Utilities Commission (PUC) for a declaratory ruling that the changes required compliance with the County's land use code. The PUC accepted the petition, and an administrative law judge (ALJ) concluded that the changes constituted "extensions, betterments, or additions" under the relevant statute, thus requiring compliance with the County's code. The PUC upheld the ALJ's decision, and the district court affirmed the PUC's ruling.The Colorado Supreme Court reviewed the case and addressed several issues raised by the railroad. The court concluded that the PUC had jurisdiction to interpret the relevant land use statute, the County had standing to petition the PUC, and the PUC did not violate the railroad's due process rights. The court also found that the PUC's determination that the changes constituted "extensions, betterments, or additions" was just and reasonable and supported by the evidence. Consequently, the Colorado Supreme Court affirmed the district court's judgment upholding the PUC's decision. View "Am. Heritage Ry.s v. Colo. Pub. Utils. Comm'n" on Justia Law

Audrey Lee Tennyson committed a series of robberies in 2007 and was charged with fifty counts. He entered a plea agreement, pleading guilty to two counts of aggravated robbery in exchange for a sentencing range of ten to thirty-two years in the Department of Corrections, to be served concurrently with sentences in three other felony cases. The plea agreement included a stipulation that Tennyson was liable for restitution, with the amount to be determined within ninety days of sentencing.The district court sentenced Tennyson to twenty-six years for each count of aggravated robbery, to run concurrently, and deferred the determination of the restitution amount. The prosecution submitted a proposed restitution order within the ninety-day period, which the court approved 136 days after sentencing. Tennyson did not object to the restitution amount within the given timeframe. Approximately ten years later, Tennyson filed a Crim. P. 35(a) claim, arguing that his sentence was illegal due to the untimely determination of the restitution amount.The Colorado Court of Appeals affirmed the district court's decision, concluding that Tennyson's claim was an illegal manner claim, not an illegal sentence claim, and was therefore time-barred as it was not filed within 120 days after sentencing.The Supreme Court of Colorado reviewed the case and held that the district court's failure to set the restitution amount within the statutory deadline did not render Tennyson's sentence illegal. Instead, it constituted an illegal manner claim, which must be brought within 120 days after sentencing. Since Tennyson did not file his claim within this period, it was time-barred. The court affirmed the judgment of the court of appeals. View "Tennyson v. People" on Justia Law

The Town of Firestone applied for conditional groundwater rights and an augmentation plan to support its growing water needs. The application included five well fields, but Firestone did not provide specific well locations for three of these fields, instead proposing to use the water court's retained jurisdiction to provide more specific details later. St. Vrain Sanitation District opposed the application, arguing that Firestone's lack of specific well locations made its depletion calculations unreliable and that relying on retained jurisdiction to prove non-injury later was legally impermissible.The District Court for Water Division 1 partially granted St. Vrain's motion to dismiss, finding that Firestone's evidence was insufficient to establish that the proposed well fields would not injure senior water rights holders. The court dismissed without prejudice the claims for the three well fields with unspecified locations and declined to retain jurisdiction, as it could not make a threshold finding of non-injury. The court also allowed St. Vrain to contest the non-injury issue at trial, despite a prior conditional stipulation.The Supreme Court of Colorado affirmed the water court's decision, holding that the water court correctly evaluated the application on a case-by-case basis and did not create a new bright-line rule requiring completed wells for conditional groundwater rights. The court also upheld the water court's refusal to retain jurisdiction without a non-injury finding and found no abuse of discretion in allowing St. Vrain to contest the non-injury issue. The Supreme Court concluded that the water court's factual findings were supported by the trial record and were not clearly erroneous. View "Town of Firestone v. BCL Colo., LP" on Justia Law

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