Colorado Case Commentaries

“Virtual Access Is Not Enough”: The Colorado Supreme Court Defines the Constitutional Floor for Public Criminal Trials in Rios v. People

Date: Aug 5, 2025

“Virtual Access Is Not Enough”: The Constitutional Requirement of Physical Public Access to Criminal Trials After Rios v. People, 2025 CO 46 I. Introduction In Rios v. People, 2025 CO 46, 572 P.3d...

Colorado Supreme Court Clarifies: No Admission of Predicate Felony Is Required to Assert the Felony‑Murder Affirmative Defense (People v. Gallegos, 2025 CO 41M)

Date: Aug 5, 2025

Colorado Supreme Court Clarifies: No Admission of Predicate Felony Is Required to Assert the Felony‑Murder Affirmative Defense Case: The People of the State of Colorado v. Kenneth Alfonso Gallegos,...

No Substitute for Presence: Colorado Supreme Court Holds Virtual-Only Access Cannot Satisfy the Sixth Amendment Public Trial Right, but COVID-Era Total Closure Was Justified Under Waller

Date: Aug 5, 2025

No Substitute for Presence: Colorado Supreme Court Holds Virtual-Only Access Cannot Satisfy the Sixth Amendment Public Trial Right, but COVID-Era Total Closure Was Justified Under Waller Introduction...

No-Admission Rule for the Felony Murder Affirmative Defense in Colorado: Commentary on People v. Gallegos, 2025 CO 41

Date: Aug 5, 2025

No-Admission Rule for the Felony Murder Affirmative Defense in Colorado Commentary on People v. Gallegos, 2025 CO 41, 572 P.3d 136 (Colo. 2025) I. Introduction In People v. Gallegos, 2025 CO 41, 572...

“Reasonably Foreseeable” Litigation Triggers a Precomplaint Duty to Preserve Evidence: Colorado Supreme Court Clarifies Spoliation Standard in Terra Management Group v. Keaten

Date: Aug 5, 2025

“Reasonably Foreseeable” Litigation Triggers a Precomplaint Duty to Preserve Evidence: Colorado Supreme Court Clarifies Spoliation Standard in Terra Management Group v. Keaten Court: Colorado Supreme...

Suspended Lawyers Forfeit Fees: Colorado PDJ Reaffirms Automatic Disbarment for Knowing Conversion and Clarifies Restitution to Third-Party Payors in People v. Vahsholtz

Date: Jul 12, 2025

Suspended Lawyers Forfeit Fees: Colorado PDJ Reaffirms Automatic Disbarment for Knowing Conversion and Clarifies Restitution to Third-Party Payors in People v. Vahsholtz Introduction This commentary...

Corporations Are “Citizens” Entitled to COML Attorney Fees; Fact-Only Disclosures Do Not Waive Attorney-Client Privilege

Date: Jul 11, 2025

Corporations Are “Citizens” Entitled to COML Attorney Fees; Fact-Only Disclosures Do Not Waive Attorney-Client Privilege Introduction In The Sentinel Colorado v. Rodriguez, 2025 CO 58, the Colorado...

Colorado Adopts a Four-Factor Reasonableness Test for Delays in Seeking Search Warrants After a Probable-Cause Seizure: People v. Mills (2025 CO 47)

Date: Jul 1, 2025

Colorado Adopts a Four-Factor Reasonableness Test for Delays in Seeking Search Warrants After a Probable-Cause Seizure: People v. Mills (2025 CO 47) Introduction In People v. Mills, 2025 CO 47, the...

Colorado Adopts Four-Factor Test for Reasonableness of Delay Between Seizure and Search Warrant Application

Date: Jul 1, 2025

Colorado Adopts Four-Factor Test for Reasonableness of Delay Between Seizure and Search Warrant Application Introduction In People v. Mills, 2025 CO 47 (Colo. 2025), the Colorado Supreme Court...

No Automatic Revival of Jury Demand After Vacatur in Dependency and Neglect Cases: Re‑Demand and Timeliness Required under § 19-3-202(2) and C.R.J.P. 4.3(a)

Date: Jul 1, 2025

No Automatic Revival of Jury Demand After Vacatur in Dependency and Neglect Cases: Re‑Demand and Timeliness Required under § 19-3-202(2) and C.R.J.P. 4.3(a) Case: The People of the State of Colorado...

Colorado Supreme Court: No Automatic Revival of a Waived Adjudicatory Jury Demand After Vacatur; New, Timely Demand Required in Dependency and Neglect Cases

Date: Jul 1, 2025

Colorado Supreme Court: No Automatic Revival of a Waived Adjudicatory Jury Demand After Vacatur; New, Timely Demand Required in Dependency and Neglect Cases Introduction In People ex rel. Kay. W. v....

No Virtual-Only Public Trials: Colorado Supreme Court Requires Physical Courtroom Access to Satisfy the Sixth Amendment (People v. Bialas, 2025 CO 45)

Date: Jun 24, 2025

No Virtual-Only Public Trials: Colorado Supreme Court Requires Physical Courtroom Access to Satisfy the Sixth Amendment Case: The People of the State of Colorado v. Michelle Re Nae Bialas, 570 P.3d...

No Order, No Restitution: Colorado Supreme Court Holds That Complete Deferral of Restitution at Sentencing Creates an Illegal Sentence and Requires Vacatur and a Subsection (1)(d) “No Restitution” Order

Date: Jun 24, 2025

No Order, No Restitution: Colorado Supreme Court Holds That Complete Deferral of Restitution at Sentencing Creates an Illegal Sentence and Requires Vacatur and a Subsection (1)(d) “No Restitution”...

“For the purpose of” is not a culpable mental state: Colorado Supreme Court holds “knowingly” is the mens rea for soliciting for child prostitution under § 18-7-402(1)(a)-(b)

Date: Jun 24, 2025

“For the purpose of” is not a culpable mental state: Colorado Supreme Court holds “knowingly” is the mens rea for soliciting for child prostitution under § 18-7-402(1)(a)-(b) Introduction In Randolph...

Restitution’s Ninety-One-Day Deadline Is Directory and Waivable: Implied Waiver Occurs When a Defendant Requests a Hearing Beyond the Statutory Period

Date: Jun 24, 2025

Restitution’s Ninety-One-Day Deadline Is Directory and Waivable: Implied Waiver Occurs When a Defendant Requests a Hearing Beyond the Statutory Period Introduction In Babcock v. People, 2025 CO 26,...

Accepting a Post–91-Day Restitution Hearing Date Waives the Statutory Deadline: Commentary on People v. Roberson, 2025 CO 30

Date: Jun 24, 2025

Accepting a Post–91-Day Restitution Hearing Date Waives the Statutory Deadline: Commentary on People v. Roberson, 2025 CO 30 Introduction In People v. Roberson, 2025 CO 30, 569 P.3d 811, the Colorado...

Mens Rea Applies to Every Element of Colorado Securities Fraud: Advice-of-Counsel Evidence Is Admissible to Negate Willfulness

Date: Jun 24, 2025

Mens Rea Applies to Every Element of Colorado Securities Fraud: Advice-of-Counsel Evidence Is Admissible to Negate Willfulness Introduction In People v. Schnorenberg, 2025 CO 43, 570 P.3d 1036 (Colo....

“Knowingly,” Not “Intentionally”: Colorado Supreme Court Clarifies Mens Rea for Soliciting for Child Prostitution under § 18-7-402(1)(a)–(b)

Date: Jun 24, 2025

“Knowingly,” Not “Intentionally”: Colorado Supreme Court Clarifies Mens Rea for Soliciting for Child Prostitution under § 18-7-402(1)(a)–(b) Introduction In Randolph v. People, 2025 CO 44, 570 P.3d...

Physical Access, Not Livestreams: Colorado Supreme Court Affirms that Virtual-Only Access Cannot Satisfy the Sixth Amendment Public Trial Right (People v. Bialas)

Date: Jun 24, 2025

Physical Access, Not Livestreams: Colorado Supreme Court Affirms that Virtual-Only Access Cannot Satisfy the Sixth Amendment Public Trial Right Commentary on People v. Bialas, 2025 CO 45 (Colo. 2025)...

Restitution Deadlines Are Directory and Waivable: Johnson v. People Extends Non‑Jurisdictional Reading to § 18‑1.3‑603(2)(a) and Confirms Waiver by Plea and Conduct

Date: Jun 24, 2025

Restitution Deadlines Are Directory and Waivable: Johnson v. People Extends Non‑Jurisdictional Reading to § 18‑1.3‑603(2)(a) and Confirms Waiver by Plea and Conduct Introduction In Johnson v. People,...