Justia Colorado Supreme Court Opinion Summaries

The case revolves around a dispute over the definition of a "dwelling" in the context of Colorado's "force-against-intruders" statute. The defendant, Joseph Howell, was involved in a physical altercation with J.M. outside his mother's apartment. At some point, Howell went inside the apartment, leaving J.M. outside on the doorstep. Howell fired a shot from inside the apartment, hitting J.M. in the face. Howell was charged with two counts of attempted first-degree murder, among other crimes. He moved to dismiss the charges, arguing that the "force-against-intruders" statute immunized him from prosecution.The district court denied Howell's motion to dismiss, finding that because J.M. never entered inside the threshold of the doorway, there was never an "unlawful entry into a dwelling," and thus, the statute does not apply. Howell appealed this decision, leading to the case being reviewed by the Supreme Court of the State of Colorado.The Supreme Court of the State of Colorado held that an uncovered, unenclosed, and unsecured doorstep is not part of a “dwelling” for the purposes of the "force-against-intruders" statute. The court reasoned that a “dwelling” must be a “building,” and a “building” is “a structure which has the capacity to contain.” Since the doorstep has no roof, walls, or gate, it does not have the capacity to contain, and therefore, it is not a “building.” The court concluded that Howell's use of force against J.M., who was standing on the doorstep and was a “non-entrant,” was not shielded by immunity under the "force-against-intruders" statute. Therefore, the court discharged the rule to show cause. View "People v. Howell" on Justia Law

The defendant, Donald L. Garcia, was convicted of first-degree motor vehicle theft by a jury. On appeal, Garcia argued that the judge who presided over his case was disqualified due to her previous involvement as a managing public defender, where she briefly covered for his lawyer in a pretrial proceeding. The court of appeals agreed with Garcia and reversed his conviction.The Supreme Court of the State of Colorado, however, disagreed with the court of appeals. The Supreme Court agreed that the judge was disqualified, but concluded that the defendant waived his claim of judicial disqualification by failing to object. The court reasoned that the defendant's attorneys were likely aware of the judge's disqualification, and their failure to object amounted to the intentional relinquishment of a known right. Therefore, the court concluded that the defendant's claim of judicial disqualification was waived.Consequently, the Supreme Court reversed the judgment of the court of appeals, reinstating Garcia's conviction and sentence. The court did not need to decide whether it is structural error requiring automatic reversal for a statutorily disqualified judge to preside over a case under the circumstances presented here, as it concluded that the defendant had waived his claim. View "People v. Garcia" on Justia Law

The Supreme Court of the State of Colorado reviewed a case involving a defendant, Charles James Crabtree, who was convicted of felony DUI. The key issue was whether the trial court erred by not presenting the element of Crabtree's relevant convictions to the jury. At the time of Crabtree's trial, the law was settled that the defendant was not entitled to have his prior convictions for alcohol-related driving offenses tried to a jury beyond a reasonable doubt. However, this law was later overturned by the Supreme Court in a separate case, Linnebur v. People, which held that the fact of a defendant’s relevant convictions in a felony DUI trial is an element of the offense that must be proved to the jury beyond a reasonable doubt.The Colorado Court of Appeals reviewed Crabtree's case for plain error and found that the trial court's error was plain at the time of appeal, even though it was not plain at the time of trial. The Court of Appeals based its decision on the U.S. Supreme Court's rulings in Johnson v. United States and Henderson v. United States, which held that an error can be considered plain if it is obvious at the time of appeal, regardless of whether it was obvious at the time of trial.The Supreme Court of the State of Colorado disagreed with the Court of Appeals' application of the Johnson and Henderson rulings. The Supreme Court held that, under Colorado law, an error must be plain at the time of trial, not at the time of appeal. The Supreme Court also clarified that the trial court's error in failing to present the element of Crabtree's relevant convictions to the jury was not a structural error requiring automatic reversal, but a trial error subject to plain error review. Because the error was not plain at the time of trial, the Supreme Court reversed the judgment of the Court of Appeals and remanded the case to the trial court for reinstatement of Crabtree's felony DUI conviction and sentence. View "People v. Crabtree" on Justia Law

The case revolves around a dispute over the validity of a will. Robert Harrison Ashworth, the deceased, had four children: Christine, Gwendolyn, Brian, and Kimberly. In 2017, Ashworth, who was in the early stages of Alzheimer's disease, executed a will that divided his estate evenly among his four children and named his son, Brian, as the estate's personal representative. However, in 2022, Ashworth executed a new will that named Christine as the personal representative and included only Christine and Gwendolyn as beneficiaries, excluding Brian and Kimberly from any inheritance. After Ashworth's death, Christine submitted the 2022 will for probate. Brian contested its validity and sought access to medical records from the last eight years of Ashworth's life, arguing that the records would shed light on Ashworth's decision-making capacity at the time he executed his final will. Christine, however, refused to provide any medical records, citing the physician-patient privilege.The trial court ordered Christine to provide the medical records for an in camera review, stating that the court would not release any records unrelated to the mental capacity of the decedent. Christine petitioned the Supreme Court of the State of Colorado for relief from the trial court's order.The Supreme Court of the State of Colorado held that the physician-patient privilege survives the privilege holder's death, but the testamentary exception provides for disclosure of the decedent's privileged medical records if they are required to administer the estate. The court discharged the rule to show cause and lifted the stay on the trial court's in camera review of Ashworth's medical records. View "In the Matter of the Estate of Ashworth" on Justia Law

In this toxic tort action, the plaintiffs claimed they were exposed to a carcinogen emitted from a plant operated by the defendants, Terumo BCT, Inc. and Terumo BCT Sterilization Services, Inc. To support their claim, the plaintiffs' counsel provided an expert with a spreadsheet detailing where each plaintiff lived and worked and when. The defendants demanded that the plaintiffs produce not only the spreadsheet but also any communications between the plaintiffs and their counsel that contained the information used to create the spreadsheet. The plaintiffs objected, arguing that such communications were privileged and beyond the scope of disclosures required by C.R.C.P. 26(a)(2). The district court granted the defendants' request and ordered the plaintiffs to produce the information.The plaintiffs sought relief under C.A.R. 21, arguing that the district court erred in finding that the attorney-client privilege does not apply to protect a client’s confidential communications of facts to trial counsel and that the disclosure of the spreadsheet to the expert did not waive the privilege. The Supreme Court of the State of Colorado agreed with the plaintiffs, concluding that the district court erred in both respects. The court held that the attorney-client privilege does apply to protect a client’s confidential communications of facts to trial counsel and that the disclosure of the spreadsheet to the expert did not waive the privilege. The court made its rule to show cause absolute and remanded the case to the district court for further proceedings. View "In Re Jordan v. Terumo BCT" on Justia Law

The case revolves around Christopher Oneil Tarr, who struck a pedestrian with his car while allegedly intoxicated. At the hospital, Tarr refused to have his blood drawn for alcohol testing, despite being informed that under Colorado’s Expressed Consent Statute, he had already consented to such a test by driving. The police proceeded with the blood draw without a warrant, and the results were used to charge Tarr with several crimes, including vehicular homicide—DUI. Tarr moved to suppress the results of the blood draws, arguing they were unconstitutional as he had clearly revoked his consent and the police did not yet have a warrant when his blood was drawn. The trial court denied the motion, and Tarr was found guilty.The trial court's decision was based on a previous case, People v. Hyde, which held that there is no constitutional right to refuse a blood-alcohol test. The court of appeals affirmed the trial court's decision, agreeing with its interpretation of Hyde. Tarr then petitioned the Supreme Court of the State of Colorado for certiorari review.The Supreme Court of the State of Colorado reversed the lower courts' decisions. It held that a conscious driver can revoke their statutory consent to a blood draw. Once consent has been revoked, the police are generally required to obtain a warrant before trying to conduct a blood draw. Otherwise, any evidence obtained from the blood draw should be excluded from trial unless one of the recognized exceptions to the exclusionary rule applies. The case was remanded for consideration of any outstanding arguments concerning the admissibility of the evidence. View "Tarr v. People" on Justia Law

The case revolves around a defendant, Sterling Dwayne Austin, who was convicted of first-degree murder. Austin's first trial ended in a mistrial due to the jury's inability to reach a unanimous verdict. During the second trial, the prosecutor used a peremptory strike to excuse a potential juror, Juror 32, due to her activism to reform the Denver Police Department. Austin challenged this strike under Batson v. Kentucky, arguing that the strike was racially motivated. The trial court denied Austin's challenge, and Juror 32 was excused.On appeal, the appellate court only addressed one of Austin's four issues, concluding that the trial court's denial of Austin's Batson challenge entitled him to a new trial. The appellate court held that the prosecutor's reason for striking Juror 32 was not race-neutral, as it was based on Juror 32's negative experiences with law enforcement, which were racially charged.The Supreme Court of the State of Colorado reversed the appellate court's decision. The Supreme Court found that the prosecutor's reason for striking Juror 32 was race-neutral, as it was based on Juror 32's potential bias against law enforcement, not her race. However, the Supreme Court also found that the trial court's findings were insufficient for an appellate court to review whether the trial court had considered all the pertinent circumstances in concluding that the strike was not made with a discriminatory purpose. Therefore, the Supreme Court remanded the case for further proceedings. View "People v. Austin" on Justia Law

The case involves a defendant, Raeaje Resshaud Johnson, who was charged with multiple counts related to a domestic violence incident. During jury selection, the prosecutor used a peremptory strike against a Black potential juror, Juror M, who had indicated in a questionnaire that law enforcement had been disrespectful to her or those close to her based on race. The defense challenged this strike under Batson v. Kentucky, alleging it violated equal protection.The trial court sustained the strike, finding that the prosecutor had provided a race-neutral reason for the strike and that the defense had not proven purposeful racial discrimination. Johnson was subsequently convicted on most counts. On appeal, Johnson argued that the trial court had erred in denying his Batson challenge. The appellate court agreed, concluding that the prosecutor's reliance on Juror M's past experiences with law enforcement was a race-based reason for the strike. The court reversed Johnson's convictions and remanded for a new trial.The Supreme Court of the State of Colorado disagreed with the appellate court's conclusion. It held that the prosecutor's reliance on Juror M's past experiences with law enforcement was a race-neutral reason for the strike. However, the Supreme Court found that the trial court had not made sufficient findings to indicate that it had considered all the pertinent circumstances in concluding that the strike was not made with a discriminatory purpose. The Supreme Court reversed the appellate court's judgment and remanded the case for further proceedings. View "People v. Johnson" on Justia Law

The defendant, Harold Lloyd Honstein, was charged with third-degree assault following an incident with his roommate, V.S. Initially, V.S. reported that Honstein had punched her and thrown a soda can at her head. However, ten months later, V.S. partially recanted her accusation, stating that Honstein had not punched her but had thrown a soda can at her head. This recantation was made in a conversation with the prosecutor and a victim advocate. The prosecutor immediately informed the defense counsel and offered to stipulate via a jury instruction that V.S. had recanted. The defense counsel, however, subpoenaed the prosecutor to testify at trial, arguing that the prosecutor was the only witness to V.S.'s first recantation. The trial court denied the prosecution's motion to quash the subpoena, ruling that there was a "compelling and legitimate need" to call the prosecutor for impeachment purposes.The prosecution appealed to the Supreme Court of the State of Colorado, arguing that the trial court had erred in ordering the prosecutor to testify. The Supreme Court agreed with the prosecution, holding that a defendant who wishes to call a participating prosecutor as a witness must demonstrate a compelling and legitimate reason to do so. The court found that the defense had not demonstrated such a reason, as the material substance of the prosecutor's testimony was available from an alternative source, namely, the investigator who had spoken with V.S. after her conversation with the prosecutor. The court concluded that the trial court had erred in ordering the prosecutor to testify and remanded the case for further proceedings consistent with its opinion. View "People v. Honstein" on Justia Law

The case revolves around Khalil Jamandre Sanders, who was charged with first-degree assault, illegal discharge of a firearm, menacing, possession of a weapon by a previous offender, and two counts of violence after shooting and injuring Jamie Vasquez during a road-rage incident. Sanders requested the presiding judge to recuse herself from the case, arguing that she had experienced a similar incident of criminal conduct, which could potentially bias her judgment. The trial court denied Sanders's motions, and the case proceeded to trial, resulting in Sanders's conviction.The Colorado Court of Appeals upheld the trial court's decision, concluding that the trial judge's recusal was not required under the Due Process Clauses of the United States and Colorado Constitutions, section 16-6-201(1)(d), C.R.S. (2023), and Crim. P. 21(b), or the Colorado Code of Judicial Conduct (“C.J.C.”) 2.11. The division determined that disqualification was not necessary because Sanders failed to demonstrate actual bias on the part of the judge.The Supreme Court of the State of Colorado affirmed the division's judgment but on somewhat different grounds. The court concluded that the division applied too strict a standard by requiring a showing of actual bias to support a disqualification motion. However, the court agreed that disqualification was not warranted on the facts of this case. The court also concluded that Sanders had not established an appearance of partiality that might have required the trial court to recuse itself under C.J.C. 2.11(A). View "Sanders v. The People of the State of Colorado" on Justia Law