lesser standard (Colorado) · Go Syfert
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lesser standard in Colorado

19 Colorado opinions name it 2 courts 1979–2026 6 in the last five years

The cases below were cited by Colorado courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
v. Jonesgreen
colo · 2020 · cited in 3 Colorado opinions naming this issue, 2025–2025
2 sentences

2025See Jones , ¶¶ 24-26, 464 P.3d at 741 (collecting cases and explaining the competing views on this issue).

2025See Jones, ¶¶ 24-26, 464 P.3d at 741 (collecting cases and explaining the competing views on this issue).

33
Victor v. Nebraskagreen
scotus · 1994 · cited in 1 Colorado opinions naming this issue, 2025–2025
1 sentence

2025See 511 U.S. 1, 27 (1994) (Ginsburg, J., concurring in part and concurring in the judgment). 16 that a reasonable doubt is “not a mere possible doubt” because everything “is open to some possible or imaginary doubt”). ¶ 32 Relying on a Hawaii case, Schlehuber contends that “firmly convinced” is more akin to the lesser standard of clear and convincing evidence than to proof beyond a reasonable doubt.

11
State v. Perezgreen
hawapp · 1998 · cited in 1 Colorado opinions naming this issue, 2025–2025
1 sentence

2025See State v. Perez, 976 P.2d 427, 442-43 (Haw.

11
Key v. Peoplegreen
colo · 1986 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See Neder v. United States, 527 U.S. 1, 16-17 (1999); Key v. People, 715 P.2d 319, 323 (Colo. 1986). ¶ 41 That is the case here.

11
Neder v. United Statesgreen
scotus · 1999 · cited in 1 Colorado opinions naming this issue, 2021–2021
1 sentence

2021See Neder v. United States, 527 U.S. 1, 16-17 (1999); Key v. People, 715 P.2d 319, 323 (Colo. 1986). ¶ 41 That is the case here.

11
Jones v. United Statesgreen
scotus · 1999 · cited in 1 Colorado opinions naming this issue, 2020–2020
1 sentence

2020See Jones v. United States, 526 U.S. 227, 249 (1999) (“[U]nlike virtually any other consideration used to enlarge the possible penalty for an offense, . . . a prior conviction must itself have been established through procedures satisfying the fair notice, reasonable doubt, and jury trial guarantees.”); Apprendi, 530 U.S. at 496 (observing that “there is a vast difference between accepting the validity of a prior judgment of conviction entered in a proceeding in which the defendant had the right to a jury trial and the right to require the prosecutor to prove guilt beyond a reasonable doubt, a

11
Apprendi v. New Jerseygreen
scotus · 2000 · cited in 1 Colorado opinions naming this issue, 2020–2020
1 sentence

2020See Jones v. United States, 526 U.S. 227, 249 (1999) (“[U]nlike virtually any other consideration used to enlarge the possible penalty for an offense, . . . a prior conviction must itself have been established through procedures satisfying the fair notice, reasonable doubt, and jury trial guarantees.”); Apprendi, 530 U.S. at 496 (observing that “there is a vast difference between accepting the validity of a prior judgment of conviction entered in a proceeding in which the defendant had the right to a jury trial and the right to require the prosecutor to prove guilt beyond a reasonable doubt, a

11
People v. Tallentgreen
colo · 2008 · cited in 1 Colorado opinions naming this issue, 2010–2010
2 sentences

2010People v. Tallent, 174 P.3d 310, 313 (Colo.2008).

2010People v. Tallent, 174 P.3d 310, 313 (Colo.2008).

11
United States v. Harold A. Thoreengreen
ca9 · 1981 · cited in 1 Colorado opinions naming this issue, 2007–2007
2 sentences

2007Unmited States v. Thoreen, 653 F.2d 1332, 1341 (9th Cir.1981); United States v. Seale, 461 F.2d 345, 366 (7th Cir.1972) 8 We find particularly persuasive other jurisdictions' consideration of the status of the con-temnor, reasoning that a party to a proceeding is held to a lesser standard of awareness of what constitutes proper conduct in the courtroom than an attorney.

2007E.g., Thoreen, 653 F.2d at 1341 (reasoning that an attorney who had years of trial experience should have been aware of the widespread custom of only allowing attorneys and parties to sit at the counsel table, such that no warning was necessary before holding him in contempt for violating this custom).

11
United States v. Bobby G. Sealegreen
ca7 · 1972 · cited in 1 Colorado opinions naming this issue, 2007–2007
1 sentence

2007Unmited States v. Thoreen, 653 F.2d 1332, 1341 (9th Cir.1981); United States v. Seale, 461 F.2d 345, 366 (7th Cir.1972) 8 We find particularly persuasive other jurisdictions' consideration of the status of the con-temnor, reasoning that a party to a proceeding is held to a lesser standard of awareness of what constitutes proper conduct in the courtroom than an attorney.

11
Colorado Auto Auction Services Corp. v. City of Commerce Citygreen
colo · 1990 · cited in 1 Colorado opinions naming this issue, 1999–1999
2 sentences

1999Under the merged “rational relationship” test, the challenging party must also “prove” the enactment unconstitutional “beyond a reasonable doubt.” Colorado Auto Auction Services Corp. v. City of Commerce City, 800 P.2d 998, 1004 (Colo.1990).

1999Under the merged "rational relationship" test, the challenging party must also "prove" the enactment unconstitutional "beyond a reasonable doubt." Colorado Auto Auction Services Corp. v. City of Commerce City, 800 P.2d 998, 1004 (Colo.1990).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Colorado. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Young v. Clark green
colo · 1991
2 sentences

2011The doctrine does not "impose a lesser standard of care on a person caught in an emergency situation; the individual is still expected to respond to the situation as a reasonably prudent person under the circumstances." Id.

2008Id.

22008–2011
William Scott Pettigrew v. The People of the State of Colorado. green
colo · 2022
1 sentence

2026The division disagreed, pointing out that the 2022 instruction “require[d] more than proof that something [wa]s highly probable.” Id. (quoting COLJI-Crim.

12026–2026
People v. Favors green
colo · 1976
2 sentences

2003In People v. Favors, 192 Colo. 136 , 556 P.2d 72 (1976), the defendant was convicted of first-degree murder after the jury considered both first and second-degree murder.

2003In People v. Favors, 192 Colo. 136 , 556 P.2d 72 (1976), the defendant was convicted of first-degree murder after the jury considered both first and second-degree murder.

12003–2003
Bradbury v. Phillips Petroleum Company green
ca10 · 1987
2 sentences

1993For example, in Bradbury v. Phillips Petroleum Co., 815 F.2d 1356 (10th Cir.1987), the court found sufficient control to support a jury finding of agency, albeit under a lesser standard, between the exploration company and a drilling company that had contracted to perform work as an independent contractor.

1993Therefore the scope of employment limitation on liability which is part of the respondeat superior doctrine is not implicit in the wrong of negligent hiring."). [17] For example, in Bradbury v. Phillips Petroleum Co., 815 F.2d 1356 (10th Cir.1987), the court found sufficient control to support a jury finding of agency, albeit under a lesser standard, between the exploration company and a drilling company that had contracted to perform work as an independent contractor.

11993–1993
United States v. Guy Mickey McNulty George O'brien, Theodore Tulper, Donald Staadts, James Nestoff and Dennis Valley green
ca10 · 1984
2 sentences

1990While our eavesdropping act is designed to protect the privacy rights of individuals, see United States v. McNulty, 729 F.2d 1243 (10th Cir.1983), we believe the lesser standard is warranted in interpreting the consent exception to its applicability.

1990While our eavesdropping act is designed to protect the privacy rights of individuals, see United States v. McNulty, 729 F.2d 1243 (10th Cir.1983), we believe the lesser standard is warranted in interpreting the consent exception to its applicability.

11990–1990
People v. Dailey green
colo · 1982
2 sentences

1988Other than our adoption of the lesser standard of a “good faith basis” 7 in the first part of the test, we held that “there is nothing in our prior opinions at variance with the stan dards and procedures set forth in Franks v. Delaware.” Dailey, 639 P.2d at 1074 .

1988Other than our adoption of the lesser standard of a "good faith basis" [7] in the first part of the test, we held that "there is nothing in our prior opinions at variance with the standards *119 and procedures set forth in Franks v. Delaware . " Dailey, 639 P.2d at 1074 .

11988–1988
Arizona v. Hicks green
scotus · 1987
1 sentence

1988The diminished standard of “reasonable suspicion,” in other words, will generally not suffice for a “plain view seizure,” because “[dispensing with the need for a warrant is worlds apart from permitting a lesser standard of cause for the seizure than a warrant would require.” Id. 4 III.

11988–1988
St. Amant v. Thompson green
scotus · 1968
2 sentences

1982Amant v. Thompson, 390 U.S. 727 , 88 S.Ct. 1323 , 20 L.Ed.2d 262 (1968), which held that reckless disregard could be found if there was “sufficient evidence to permit the conclusion that the defendant in fact entertained serious doubts as to the truth of his publication.” Id. at 731 , 88 S.Ct. at 1325 .

1982Amant v. Thompson, 390 U.S. 727 , 88 S.Ct. 1323 , 20 L.Ed.2d 262 (1968), which held that reckless disregard could be found if there was “sufficient evidence to permit the conclusion that the defendant in fact entertained serious doubts as to the truth of his publication.” Id. at 731 , 88 S.Ct. at 1325 .

11982–1982
People v. Kanan green
colo · 1974
1 sentence

1979Authorities such as In re Winship and People v. Kanan, supra , do not decide the issue, but rather reaffirm the principle that the prosecution must adhere to the standard of proof beyond a reasonable doubt, rather than a lesser standard, in overcoming the presumption of innocence of the accused in a criminal case.

11979–1979

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 18-1-501 (3) CO § Colo. Rev. Stat. § 18-3-103 (3) CO § Colo. Rev. Stat. § 18-3-104 (3) CO § Colo. Rev. Stat. § 18-3-105 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 182 (1906–2026) TX 127 (1970–2026) OH 118 (1973–2025) NY 114 (1933–2026) IL 112 (1962–2025) PA 101 (1974–2026) IN 75 (1974–2026) LA 70 (1967–2025) FL 69 (1974–2025) WA 55 (1980–2026) CT 51 (1976–2024) MI 48 (1979–2026) GA 42 (1924–2023) NJ 41 (1953–2026) MD 41 (1975–2026) DC 34 (1970–2024) MA 33 (1966–2025) VA 31 (1982–2024) AZ 29 (1977–2026) KS 27 (1977–2026) AL 22 (1979–2024) TN 21 (1989–2026) OR 20 (1969–2023) CO 19 (1979–2026) WI 18 (1925–2023) NM 17 (1975–2017) MN 17 (1980–2014) OK 17 (1962–2022) MO 16 (1987–2020) MS 16 (1987–2025) IA 15 (1974–2022) NC 14 (1958–2026) KY 13 (1964–2024) AR 12 (1983–2023) ID 12 (1980–2014) WV 12 (1979–2022) AK 12 (1977–2017) VT 12 (1975–2020) MT 11 (2005–2026) RI 11 (1983–2011) SC 10 (1989–2020) NE 10 (1982–2023) UT 9 (1929–2024) DE 9 (1973–2026) ND 9 (1990–2016) WY 9 (1990–2022) SD 6 (1979–2008) ME 6 (1981–2018) NH 6 (1980–2019) HI 5 (1984–2007) NV 5 (1997–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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