Justia Criminal Law Opinion Summaries

The case involves Glen Gary Montoya, who was arrested on suspicion of driving under the influence (DUI). After initially agreeing to a blood test, Montoya later refused. However, after the nurse left, he changed his mind and requested to take the test. The test was not conducted. At trial, the prosecution sought to use Montoya’s refusal as evidence of consciousness of guilt. Montoya was found guilty of DUI and careless driving.The Colorado Court of Appeals concluded that if a criminal court determines that a driver refused testing, that determination must be based on the law of refusal that has developed in the administrative, license-revocation context. The court also concluded that if the prosecutor seeks to use as evidence a defendant’s refusal of a chemical test, but the defendant disputes refusal, the entire circumstances surrounding the defendant’s test-taking must be submitted for the jury’s consideration. The court reversed Montoya’s DUI conviction and remanded for a new trial.The Supreme Court of the State of Colorado disagreed with the lower court's interpretation of the law of refusal. The Supreme Court held that criminal DUI trials are governed by the same evidentiary rules as any other criminal trial. Therefore, criminal courts are not bound by the law of refusal that governs administrative, license-revocation hearings. The court also concluded that the district court erred by admitting evidence of Montoya's refusal to submit to testing and excluding evidence of his subsequent request for testing. The Supreme Court affirmed in part and reversed in part the decision of the lower court, remanding the case for a new trial. View "People v. Montoya" on Justia Law

Brandon Mason Bohler was charged with first-degree murder after stabbing his roommate to death. He pleaded not guilty by reason of insanity. During his arrest, Bohler made statements to the police which were later suppressed by the district court. The court ruled that Bohler was in custody for Miranda purposes when he made the statements, and thus, they should have been preceded by a Miranda warning.The People of the State of Colorado appealed the district court's decision to suppress Bohler's statements. They argued that Bohler was not in custody when he made the statements, and therefore, a Miranda warning was not required. The appeal was brought before the Supreme Court of the State of Colorado.The Supreme Court of the State of Colorado reversed the district court's decision. The court determined that Bohler was not in custody when he made the statements. The court reasoned that a reasonable person in Bohler's position would not have believed himself to be deprived of freedom of action to the degree associated with a formal arrest. Therefore, the court concluded that the district court erred in suppressing Bohler's statements, and remanded the case for further proceedings consistent with its opinion. View "People v. Brandon Bohler" on Justia Law

The Supreme Court of the State of Colorado affirmed a lower court's restitution order, ruling that the defendant was the proximate cause of the victim's pecuniary loss. The defendant, Arnold Roman Martinez, had stolen a bicycle and was pursued by the bicycle's owner in a car. The car was damaged when the owner cut off Martinez, causing him to crash into the car. The district court ordered Martinez to pay over $2,000 in restitution for the damage to the car.On appeal, Martinez challenged the order, asserting that he did not proximately cause the damage to the car. The Supreme Court of the State of Colorado ruled that the standard for reviewing a district court's determination of proximate cause for criminal restitution is clear error, not the abuse-of-discretion standard used by the lower court. The Supreme Court found that the district court did not clearly err in determining that Martinez's theft was the proximate cause of the damage to the car. Therefore, the Supreme Court affirmed the restitution order on different grounds. View "Martinez v. People" on Justia Law

The Supreme Court of Colorado examined the case of Carlos Ray Maes, who was charged with six felony counts. A magistrate presided over the preliminary hearing and found that probable cause existed for each of the eligible counts. The case was then bound over to the district court. Nearly three months later, Maes petitioned the district court for a review of the magistrate's probable-cause determination, but the district court declined, arguing that it did not have jurisdiction to review such a determination and that Maes's petition was not timely.The Supreme Court of Colorado held that a magistrate's finding of probable cause after a preliminary hearing is a "final order or judgment" under the Colorado Rules for Magistrates and is therefore reviewable by a district court. Further, the court held that the time limit for petitioning for district court review of a magistrate's final order or judgment begins when the magistrate memorializes that determination in writing. Consequently, the court concluded that Maes's petition was timely filed. The court made the rule to show cause absolute and remanded the case for further proceedings consistent with its opinion. View "People v. Maes" on Justia Law

This case involves the interpretation of a provision in the Colorado Sex Offender Lifetime Supervision Act (SOLSA) that dictates the factors parole boards must consider when deciding whether to release a convicted sex offender on parole. The Supreme Court of Colorado was asked by the Tenth Circuit Court of Appeals to determine whether SOLSA requires, permits, or prohibits parole boards from considering maturity and rehabilitation of an offender.The case arose from the sentencing of Omar Ricardo Godinez, who was convicted of several serious offenses committed when he was fifteen years old. Godinez argued that SOLSA violated the Eighth Amendment as applied to him, claiming that the Act does not allow parole boards to consider an offender's maturity and rehabilitation. This, he contended, renders the Act unconstitutional in light of the Supreme Court's decision in Graham v. Florida, which mandates that young offenders must be given "some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation."The Supreme Court of Colorado concluded that although SOLSA does not expressly require parole boards to consider an offender's maturity, it does not prevent them from doing so. Hence, SOLSA permits consideration of maturity. As for rehabilitation, the Court held that it is a necessary part of the factors the parole board is required to consider under SOLSA. Thus, the Court concluded that SOLSA requires consideration of rehabilitation. Therefore, the Court held that SOLSA permits consideration of maturity and requires consideration of rehabilitation. View "Godinez v. Williams" on Justia Law

In a case before the Supreme Court of the State of Colorado, the defendant, Sir Mario Owens, appealed his convictions for first-degree murder, witness intimidation, conspiracy to commit first-degree murder, and accessory to a crime. The convictions stemmed from two separate incidents: the Lowry Park shootings, in which Owens was involved, and the subsequent Dayton Street shootings, for which Owens was convicted. The defendant argued that the trial was unfair due to the court's rulings on several issues, including the admission of evidence related to the Lowry Park shootings, the denial of Owens's motions for mistrial, and the limitation on cross-examination and impeachment of the prosecution's key witness. The Supreme Court held that the trial court's rulings were proper and did not constitute reversible error. Consequently, the Supreme Court affirmed the judgment of conviction. View "People v. Owens" on Justia Law

In the case before the Supreme Court of the State of Colorado, Arnold Roman Martinez stole a bicycle from the garage of C.T. Pursuing Martinez in his car, C.T. pulled in front of Martinez, leading to a collision that damaged C.T.’s vehicle. Martinez was subsequently ordered to pay restitution for the damage to the car as part of a plea agreement in a criminal case. Martinez contested the restitution order, arguing that he did not proximately cause the car damage.The Supreme Court held that the appropriate standard of review for evaluating a district court’s determination of proximate cause for restitution is clear error, not abuse of discretion as had been applied by the lower courts. The court reasoned that the proximate cause inquiry is primarily a fact-based determination, and that trial courts are better situated to resolve such disputes. It also noted that the statutory language and structure suggest that the standard of review should allow for expedient resolution of restitution decisions.Applying this standard, the Supreme Court found no clear error in the district court’s determination that Martinez had proximately caused the car damage. The court determined that C.T.’s actions were foreseeable and not grossly negligent, and that Martinez had participated in the events leading to the collision. Therefore, the Supreme Court affirmed the lower court's decision that Martinez was obligated to pay restitution. View "Martinez v. People" on Justia Law

In the case before the Supreme Court of the State of Colorado, the court had to decide whether Anthony Robert Smith had waived some of the claims he had raised in a pro se Crim. P. 35(c) motion by not pursuing certain claims in later briefings and at a postconviction hearing. The court also had to consider whether counsel could abandon some of a defendant’s pro se Crim. P. 35(c) claims without first obtaining the defendant’s informed consent, and whether abandonment of individual postconviction claims requires a showing of intent to do so.Smith was convicted of multiple counts of sexual assault on a child and promotion of obscenity to a minor. After his conviction was affirmed by the court of appeals, Smith filed a pro se Crim. P. 35(c) motion, asserting several claims of ineffective assistance of counsel and prosecutorial misconduct. After appointed counsel filed a Supplemental Motion for Post-Conviction Relief that did not include some of Smith's pro se claims, the postconviction court found that Smith had waived those omitted claims.On appeal, a division of the court of appeals reversed the postconviction court’s decision, concluding that Smith’s claims were preserved because they were not superseded by counsel’s motion. The Supreme Court of the State of Colorado disagreed and reversed the judgment of the court of appeals.The Supreme Court of the State of Colorado held that Smith abandoned the claims he stopped pursuing. The court also decided that counsel, as the “captain of the ship,” has the authority to make strategic decisions, including which claims to pursue. Therefore, counsel may abandon some of a defendant’s pro se Crim. P. 35(c) claims without the client’s informed consent. The court did not rule on whether abandonment of individual postconviction claims requires a showing of intent to abandon such claims. View "People v. Smith" on Justia Law

In this criminal case, James Herman Dye was charged with murdering a woman over forty years ago. During pretrial hearings, Dye indicated that he might present evidence suggesting another person, an alternate suspect, committed the crime. The Supreme Court of Colorado clarified that the Colorado Rules of Criminal Procedure (“Discovery and Procedure Before Trial”) Rule 16(II)(c) requires a defendant to disclose the nature of any defense, including an alternate suspect defense, prior to trial. The Court also clarified that the requirement to disclose the nature of a defense includes identifying any alternate suspects, along with their addresses if they are to be called to testify at trial. However, the Court found that the lower court's order for Dye to disclose "all evidence" related to the alternate suspect defense was overbroad. The Court ruled that the prosecution should conduct its own investigation into any alternate suspect identified. The Court also held that disputes over the admissibility of alternate suspect evidence should be resolved prior to trial. The Court therefore vacated the lower court’s discovery order and directed the lower court to follow the procedures outlined in its opinion. View "People v. Dye" on Justia Law

The Supreme Court of the State of Colorado affirmed the district court's order to suppress inculpatory statements made by the defendant, John J. Sanders Jr., in a case involving alleged sexual assault on a child. The district court concluded that Sanders's statements were elicited during a custodial interrogation without proper Miranda warnings and were not voluntary. The People appealed, challenging the district court's ruling on custody but failing to sufficiently challenge the court's separate ruling on voluntariness. The Supreme Court affirmed the district court's order, stating that even if they agreed with the People on the issue of custody, they must affirm the district court's suppression order due to the unchallenged finding of involuntariness. View "People v. Sanders" on Justia Law