prosecutorial misconduct claim (Colorado) · Go Syfert
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prosecutorial misconduct claim in Colorado

10 Colorado opinions name it 2 courts 2017–2026 7 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 (7)

CaseFollowedCited
Wend v. Peoplegreen
colo · 2010 · cited in 6 Colorado opinions naming this issue, 2017–2026
2 sentences

2026Wend, 235 P.3d at 1096 .

2019Wend v. People, 235 P.3d 1089, 1096 (Colo. 2010). ¶ 30 Where, as here, a defendant does not object to the challenged conduct at trial, we review a prosecutorial misconduct claim for plain error.

36
People v. Avilagreen
coloctapp · 1997 · cited in 1 Colorado opinions naming this issue, 2026–2026
1 sentence

2026For prosecutorial misconduct to constitute plain error, the conduct must be “flagrantly, glaringly, or tremendously improper” and “so undermine[] the fundamental fairness of the trial 11 itself as to cast serious doubt on the reliability of the jury’s verdict.” Domingo-Gomez, 125 P.3d at 1053 (quoting People v. Avila, 944 P.2d 673, 676 (Colo. App. 1997)). ¶ 23 In analyzing a prosecutorial misconduct claim, the reviewing court must determine (1) whether the prosecutor’s questionable conduct was improper based on the totality of the circumstances, and (2) whether such actions warrant reversal ac

11
Wilson v. Peoplegreen
colo · 1987 · cited in 1 Colorado opinions naming this issue, 2025–2025
1 sentence

2025An error is substantial if it “so undermined the fundamental fairness of the trial itself as to cast serious doubt on the reliability of the judgment of conviction.” Id. at ¶ 43 (quoting Wilson v. People, 743 P.2d 415, 420 (Colo. 1987)). ¶ 50 In reviewing a prosecutorial misconduct claim, we conduct a two-step analysis.

11
People v. Gladneygreen
coloctapp · 2010 · cited in 1 Colorado opinions naming this issue, 2024–2024
1 sentence

2024A prosecutor is entitled to “employ rhetorical devices and engage in oratorical embellishment and metaphorical nuance,” People v. Gladney, 250 P.3d 762, 769 (Colo. App. 2010) (citation omitted), and enjoys “considerable latitude in replying to opposing counsel’s arguments,” People v. Conyac, 2014 COA 8M, ¶ 133 .

11
People v. Geisendorfergreen
coloctapp · 1999 · cited in 1 Colorado opinions naming this issue, 2024–2024
1 sentence

2024When evaluating a prosecutorial misconduct claim relating to closing argument, we look to the “context of the argument as a whole and in light of the evidence before the jury.” People v. Geisendorfer, 991 P.2d 308, 312 (Colo. App. 1999).

11
12 CAW Equities v. City of Greenwood Villagegreen
coloctapp · 2018 · cited in 1 Colorado opinions naming this issue, 2020–2020
1 sentence

2020People v. Galvan, 2019 COA 68, ¶ 57 (cert. granted Jan. 13, 2020). ¶ 105 “Whether a prosecutor committed misconduct is an issue within the trial court’s discretion.” People v. Van Meter, 2018 COA 42 13, ¶ 25 .

11
v. Galvangreen
coloctapp · 2019 · cited in 1 Colorado opinions naming this issue, 2020–2020
1 sentence

2020People v. Galvan, 2019 COA 68, ¶ 57 (cert. granted Jan. 13, 2020). ¶ 105 “Whether a prosecutor committed misconduct is an issue within the trial court’s discretion.” People v. Van Meter, 2018 COA 42 13, ¶ 25 .

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 (4)

CaseCitedYears
Domingo-Gomez v. People green
colo · 2005
2 sentences

2026For prosecutorial misconduct to constitute plain error, the conduct must be “flagrantly, glaringly, or tremendously improper” and “so undermine[] the fundamental fairness of the trial 11 itself as to cast serious doubt on the reliability of the jury’s verdict.” Domingo-Gomez, 125 P.3d at 1053 (quoting People v. Avila, 944 P.2d 673, 676 (Colo. App. 1997)). ¶ 23 In analyzing a prosecutorial misconduct claim, the reviewing court must determine (1) whether the prosecutor’s questionable conduct was improper based on the totality of the circumstances, and (2) whether such actions warrant reversal ac

2022A defendant asserting plain error in this context must show that the prosecutor’s misconduct was “flagrantly, glaringly, or tremendously improper,” Domingo-Gomez, 125 P.3d at 1053 , and we have observed that prosecutorial misconduct in closing argument rarely is so egregious as to satisfy this standard, Constant, 645 P.2d at 847 . 8 ¶67 Applying these principles here, I cannot say that the prosecution’s remarks rose to the level of plain error.

22022–2026
People v. Samson green
coloctapp · 2012
1 sentence

2025People v. Samson, 2012 COA 167, ¶ 30 .

12025–2025
People v. Constant green
colo · 1982
1 sentence

2022A defendant asserting plain error in this context must show that the prosecutor’s misconduct was “flagrantly, glaringly, or tremendously improper,” Domingo-Gomez, 125 P.3d at 1053 , and we have observed that prosecutorial misconduct in closing argument rarely is so egregious as to satisfy this standard, Constant, 645 P.2d at 847 . 8 ¶67 Applying these principles here, I cannot say that the prosecution’s remarks rose to the level of plain error.

12022–2022
People v. Rhea green
coloctapp · 2014
1 sentence

2019People v. Rhea, 2014 COA 60, ¶ 43 .

12019–2019

Where else courts name it

WA 175 (1985–2026) CA 79 (1973–2026) KS 69 (2001–2025) IN 25 (1996–2025) OH 18 (1992–2026) UT 18 (1992–2024) IA 17 (1986–2026) PA 15 (2012–2025) NM 12 (2009–2024) CT 11 (1995–2017) TX 10 (2012–2025) CO 10 (2017–2026) WY 8 (1998–2025) NV 7 (1986–2021) ID 6 (2010–2025) MI 6 (2008–2025) MN 6 (2001–2019) AZ 6 (1998–2025) DE 6 (2014–2026) TN 6 (1999–2020) IL 5 (2020–2022) HI 4 (2003–2025) OK 4 (2006–2023) FL 3 (2006–2017) SD 3 (2014–2026) NE 2 (2016–2018) VI 2 (2011–2014) AR 2 (2000–2020)

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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