Justia Constitutional Law Opinion Summaries

In an interlocutory appeal, the issue this case presented to the Colorado Supreme Court was whether the trial court erred when it suppressed evidence that the police found in defendant-appellee Lynette Webb's purse. In a visit with defendant's son, officers found spoons with methamphetamine residue under the son's bed, and a syringe that tested positive for methamphetamine in a visitor's backpack. Upon executing a search warrant of the house (and all personal property within) based on the visit with the son, officers found methamphetamine paraphernalia in defendant's purse. The trial court concluded that defendant had a heightened expectation of privacy to the purse, and that officers' search was unreasonable because it was unlikely that the son would hide contraband in his mother's purse. The Supreme Court concluded the trial court applied the wrong analysis: "[o]nce a lawful search warrant is issued, the scope of the search is defined by the scope of the warrant rather than an individual's expectation of privacy in any particular area or item." The Court therefore reversed the trial court's ruling and remanded the case for further proceedings. View "Colorado v. Webb" on Justia Law

Defendant-appellant Dennis Sanchez appealed the court of appeals' judgment affirming his conviction for sexual assault on a child as part of a pattern of abuse. The trial court entered judgment of conviction for a class 3 felony on "Sexual Assault on a Child - Pattern of Abuse", notwithstanding the jury's verdict of "not guilty" on the charge entitled "Sexual Assault on a Child," based on a separate finding of two of six enumerated touching incidents presented on a verdict form entitled "Sexual Assault on a Child - Pattern of Abuse." A majority of the appeals court concluded defendant had been adequately charged in a single count and that the jury's instructions did not make its finding of a pattern of abuse contingent upon first finding the defendant's guilt of the separately charged crime of "Sexual Assault of a Child." The Supreme Court reversed the conviction, finding that because the verdict form the jury used never offered the jury the opportunity to find that defendant committed the elements of sexual assault on a child, and instead reflected at most, the jury's factual finding of two different incidents of sexual contact. The trial court erred in entering judgment for a class 3 felony and as such, the court of appeals' judgment affirming the trial court was error. View "Sanchez v. Colorado" on Justia Law

Police arrested Jeffrey Knedler for allegedly assaulting two people. Days after the assault, officers contacted Knedler at a hair salon where he occasionally stayed. As they approached the salon, the officers observed Knedler drinking from what appeared to be a liquor bottle. He also took a long drink from an alcoholic beverage before officers handcuffed him and placed him in a police car. Knedler agreed to speak with an investigator, but he did not want to talk in the police car, so he was taken to police headquarters. Upon arriving at headquarters, Knedler was presented with a written Miranda advisement, and it was read aloud to him. Knedler stated he did not have his glasses with him to read the advisement and waiver, but he initialed by each of the numbered rights, signed the advisement and waiver and stated "I know my rights." After questioning, Knedler admitted to beating both victims and made numerous incriminating statements. The State sought reversal of the trial court's order that suppressed videotaped statements Knedler made after he signed the written waiver of his Miranda rights. Based on Knedler's extremely high blood alcohol contend at the time of the waiver, the trial court found the waiver was invalid. Because Knedler's waiver was nonetheless knowing and intelligent, the Supreme Court reversed the suppression order. View "Colorado v. Knedler" on Justia Law

Ascension Baez-Lopez, Jose Soto-Lopez and Juan Cantu-Bojorquez were indicted on counts of violating the Colorado Organized Crime Control Act, and counts of conspiracy to distribute a Schedule II controlled substance. The issue before the Colorado Supreme Court in this matter centered on he trial court’s order suppressing evidence from interceptions of oral and wire communications in these three cases. The trial court suppressed the “wiretap” recordings on grounds that they had not been sealed in compliance with state law and no satisfactory explanation for the absence of the seal given. Upon review, the Supreme Court concluded that the trial court abused its discretion in granting the suppression motions because the sealing procedure indeed complied with the applicable state law. Accordingly, the Court reversed the trial court’s order. View "Colorado v. Baez-Lopez" on Justia Law

Prosecutors alleged defendant Ricky Hoang instigated a home invasion robbery involving three others stealing jewelry and cash at gunpoint. Defendant was restrained with leg shackles during his jury trial over his repeated objections. The issues this case presented to the Supreme Court were: (1) whether the trial court erred by requiring defendant to be tried with the shackles without a finding of specific need; and (2) whether defendant’s claims of delays and deficiencies in producing the record violated his rights to a meaningful and speedy appeal. The Supreme Court held that “When the record does not show the restrains were plainly visible, the defendant must point to something in the record justifying an appellate court’s reasonable inference that at least one juror saw or heard them. If defendant fails to meet that burden, then the constitutional harmless error standard . . . does not apply.” Furthermore, the Court concluded that defendant’s rights to a meaningful and speedy appeal were not violated. View "Hoang v. Colorado" on Justia Law

At issue in this case was Election Rule 10.7.5, promulgated as a temporary or emergency rule on the evening of the November 5, 2013 election. Plaintiffs were registered electors of the Adams 12 Five Star School District who sued seeking judicial review of the Secretary of State's authority to promulgate the rule, and for an order to direct the Clerk and Recorder of Adams County to finish counting votes and to certify the vote tally for all candidates in the school district director election. The district court ruled that the Secretary acted in excess of his authority in promulgating the emergency rule, and ordered all defendants to complete and certify the vote count for all candidates in the Adams 12 director district 4 election. The Secretary petitioned the Supreme Court for review of whether the district court erred in holding "Rule 10.7.5 [was] contrary to and in conflict with existing election statutes." Upon review, the Supreme Court concluded that Rule 10.7.5 indeed "contravene[d] the election code by permitting a designated election official to usurp the courts' express authority to resolve . . . issues." Accordingly, the Court affirmed the district court only in holding that Rule 10.7.5 conflicted with existing election rules. View "Hanlen v. Gessler" on Justia Law

The issue for the Supreme Court's consideration in this case was the balance between a defendant's Sixth Amendment constitutional right to counsel of his or her choice and the public's interest in the fairness and efficiency of the judicial system. The Court of appeals developed a balancing test for a trial court to use when deciding whether to grant or deny a defendant's request for a continuance so that s/he may change counsel. The appellate court applied its test to the facts of this case and determined that the trial court abused its discretion and violated the defendant's constitutional rights to counsel of choice when it denied a request for a continuance. As a result, the appellate court reversed defendant's conviction and remanded the case for a new trial. The State appealed that outcome. While the Supreme Court agreed with the Court of Appeals that the decision whether to grant a continuance is a fact-based question best decided by the trial court, it declined to adopt the appellate court's test because it did not adequately reflect longstanding precedent requiring consideration of the "totality of the circumstances" when deciding on whether to grant a continuance. The Court concluded that the trial court record in this case was inadequate to determine whether the trial court abused its discretion when it denied the continuance. Accordingly, the Court reversed the appellate court's decision and remanded the case back to the trial court for additional findings and conclusions. View "Colorado v. Brown" on Justia Law

The State appealed the Court of Appeals' reversal of defendant's convictions for first degree assault and first degree burglary, and his sentence of 28 years' imprisonment. The appellate court concluded the trial court abused its discretion in denying a challenge for cause on the grounds of juror bias, and that the defendant removed the juror in question with a peremptory challenge, and then exhausted his remaining peremptory challenges. The appellate court reversed noting the Supreme Court's rule of automatic reversal, as explained in "Colorado v. Macrander" (828 P.2d 234 (1992)). The State petitioned the Supreme Court solely to request reconsideration of automatic reversal under these circumstances. The Supreme Court overruled the automatic reversal requirement of "Macrander." Because the Court of Appeals relied on the bright-line automatic reversal rule of "Macrander," rather than evaluating the likely effect of the trial court's error on the outcome of the specific case in which it occurred, the Supreme Court reversed the appellate court and remanded the case for reconsideration in light of this holding. View "Colorado v. Montero-Romero" on Justia Law

The State appealed the Court of Appeals' reversal of defendant's convictions for theft by receiving and his sentence to three years' probation. The appellate court concluded the trial court abused its discretion in denying a challenge for cause on the grounds of juror bias, and that defendant removed the juror with a peremptory challenge and then exhausted his remaining peremptory challenges. The appellate court reversed noting the Supreme Court's rule of automatic reversal, as explained in "Colorado v. Macrander" (828 P.2d 234 (1992)). The State petitioned the Supreme Court solely to request reconsideration of automatic reversal under these circumstances. Because the Court of Appeals relied on the bright-line automatic reversal rule of "Macrander," rather than evaluating the likely effect of the trial court's error on the outcome of the specific case in which it occurred, the Supreme Court reversed the appellate court and remanded the case for reconsideration in light of this holding. View "Colorado v. Roldan" on Justia Law

Following defendant's conviction for manslaughter, the trial court delayed sentencing to await resolution of an unrelated felony charge. Defendant pled guilty to that felony. The manslaughter case thereafter proceeded to sentencing. At the rescheduled hearing, the trial court found that the unrelated felony triggered sentencing within an aggravated range. Defendant was then sentenced to twice the maximum presumptive sentence (in this case, twelve years) for manslaughter. The Court of Appeals found the manslaughter sentencing delay unreasonable, also holding that defendant's right to speedy trial was violated. The Supreme Court reversed the Court of Appeals: the six-month, seven-day delay was not unreasonable under Colo. Crim. P. 32(b) because the trial court imposed the delay for a legally justifiable reason. Furthermore, the Court rejected defendant's constitutional claim, holding the delay was no presumptively prejudicial. View "Colorado v. Sandoval-Candelaria" on Justia Law