lesser nonincluded offense instruction (Colorado) · Go Syfert
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lesser nonincluded offense instruction in Colorado

5 Colorado opinions name it 1 courts 2006–2025 1 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 (9)

CaseFollowedCited
People v. Trujillogreen
colo · 2004 · cited in 2 Colorado opinions naming this issue, 2013–2018
2 sentences

2018A court abuses its discretion when its decision is 19 “manifestly arbitrary, unreasonable, or unfair.” People v. Ibarra, 849 P.2d 33, 38 (Colo. 1993). ¶ 45 A defendant is entitled to a lesser nonincluded offense instruction as part of his defense theory if the evidence provides a rational basis to support a “verdict acquitting [the defendant] of a greater offense . . . and convicting [the defendant] of the lesser offense.” People v. Trujillo, 83 P.3d 642, 645 (Colo. 2004) (quoting Bartowsheski, 661 P.2d at 242 ).

2018A court abuses its discretion when its decision is 19 “manifestly arbitrary, unreasonable, or unfair.” People v. Ibarra, 849 P.2d 33, 38 (Colo. 1993). ¶ 45 A defendant is entitled to a lesser nonincluded offense instruction as part of his defense theory if the evidence provides a rational basis to support a “verdict acquitting [the defendant] of a greater offense . . . and convicting [the defendant] of the lesser offense.” People v. Trujillo, 83 P.3d 642, 645 (Colo. 2004) (quoting Bartowsheski, 661 P.2d at 242 ).

22
People v. Wartenagreen
coloctapp · 2012 · cited in 2 Colorado opinions naming this issue, 2013–2025
2 sentences

2025The “consent” element in his proposed lesser nonincluded jury instruction does not refer to the victim’s consent to sexual conduct but to the victim’s consent to her intimate parts being photographed. § 18-7-801; see also People v. Wartena, 2012 COA 12, ¶ 36 (“A lesser nonincluded offense instruction is tantamount to a defendant’s theory of the case instruction” and “is in the nature of a strategy” (quoting People v. Skinner, 825 P.2d 1045, 1047-48 (Colo. App. 1991). ¶ 68 We conclude that the trial court did not abuse its discretion by refusing to instruct the jury on the lesser-included offen

2013People v. Wartena, 2012 COA 12 , ¶ 36, 296 P.3d 136 .

12
People v. Skinnergreen
coloctapp · 1991 · cited in 2 Colorado opinions naming this issue, 2006–2025
2 sentences

2025The “consent” element in his proposed lesser nonincluded jury instruction does not refer to the victim’s consent to sexual conduct but to the victim’s consent to her intimate parts being photographed. § 18-7-801; see also People v. Wartena, 2012 COA 12, ¶ 36 (“A lesser nonincluded offense instruction is tantamount to a defendant’s theory of the case instruction” and “is in the nature of a strategy” (quoting People v. Skinner, 825 P.2d 1045, 1047-48 (Colo. App. 1991). ¶ 68 We conclude that the trial court did not abuse its discretion by refusing to instruct the jury on the lesser-included offen

2006"Normally, by asking for a lesser nonincluded offense instruction, the defendant will deny the original charge, but admit committing a lesser offense which carries a less severe penalty." Skinner, supra, 825 P.2d at 1047 .

12
People v. Garciagreen
colo · 1997 · cited in 2 Colorado opinions naming this issue, 2006–2013
2 sentences

2013People v. Rubio, 222 P.3d 355 , 361 (Colo.App.2009) ; see also People v. Trujillo, 83 P.3d 642 , 645 (Colo.2004) ; Garcia, 940 P.2d at 361 . ¶ 91 The offense of false reporting occurs when "[a person] makes a report or knowingly causes the transmission of a report to law enforcement authorities of a crime or other incident within their official concern when he knows that it did not occur." § 18-8-111(1)(b).

2006A defendant's request for a lesser nonincluded offense instruction "is tantamount to a defendant's consent to an added count being charged against him." People v. Rivera, 186 Colo. 24, 28-29 , 525 P.2d 431, 434 (1974); accord People v. Garcia, 940 P.2d 357, 361 (Colo.1997).

12
People v. Jimenezgreen
coloctapp · 2008 · cited in 1 Colorado opinions naming this issue, 2019–2019
1 sentence

2019People v. Jimenez, 217 P.3d 841, 870 (Colo. App. 2008).

11
People v. Ibarragreen
colo · 1993 · cited in 1 Colorado opinions naming this issue, 2018–2018
2 sentences

2018A court abuses its discretion when its decision is 19 “manifestly arbitrary, unreasonable, or unfair.” People v. Ibarra, 849 P.2d 33, 38 (Colo. 1993). ¶ 45 A defendant is entitled to a lesser nonincluded offense instruction as part of his defense theory if the evidence provides a rational basis to support a “verdict acquitting [the defendant] of a greater offense . . . and convicting [the defendant] of the lesser offense.” People v. Trujillo, 83 P.3d 642, 645 (Colo. 2004) (quoting Bartowsheski, 661 P.2d at 242 ).

2018A court abuses its discretion when its decision is 19 “manifestly arbitrary, unreasonable, or unfair.” People v. Ibarra, 849 P.2d 33, 38 (Colo. 1993). ¶ 45 A defendant is entitled to a lesser nonincluded offense instruction as part of his defense theory if the evidence provides a rational basis to support a “verdict acquitting [the defendant] of a greater offense . . . and convicting [the defendant] of the lesser offense.” People v. Trujillo, 83 P.3d 642, 645 (Colo. 2004) (quoting Bartowsheski, 661 P.2d at 242 ).

11
People v. Nozolinogreen
coloctapp · 2014 · cited in 1 Colorado opinions naming this issue, 2018–2018
1 sentence

2018But whether “the record contains sufficient evidence to support instruction on a lesser offense is a factual inquiry reviewed for an abuse of discretion.” Id. at ¶ 30; People v. Nozolino, 2014 COA 95, ¶ 43 (“Because the district court denied [the] instruction on a factual basis, we review for an abuse of discretion.”); cf. People v. Montante, 2015 COA 40, ¶ 32 (“We review de novo the trial court’s refusal to give the lesser nonincluded offense instruction because the court’s determination that the medical marijuana registry fraud statute is inapplicable to defendant’s conduct is a question of

11
People v. Montantegreen
coloctapp · 2015 · cited in 1 Colorado opinions naming this issue, 2018–2018
1 sentence

2018But whether “the record contains sufficient evidence to support instruction on a lesser offense is a factual inquiry reviewed for an abuse of discretion.” Id. at ¶ 30; People v. Nozolino, 2014 COA 95, ¶ 43 (“Because the district court denied [the] instruction on a factual basis, we review for an abuse of discretion.”); cf. People v. Montante, 2015 COA 40, ¶ 32 (“We review de novo the trial court’s refusal to give the lesser nonincluded offense instruction because the court’s determination that the medical marijuana registry fraud statute is inapplicable to defendant’s conduct is a question of

11
People v. Riveragreen
colo · 1974 · cited in 1 Colorado opinions naming this issue, 2006–2006
2 sentences

2006A defendant's request for a lesser nonincluded offense instruction "is tantamount to a defendant's consent to an added count being charged against him." People v. Rivera, 186 Colo. 24, 28-29 , 525 P.2d 431, 434 (1974); accord People v. Garcia, 940 P.2d 357, 361 (Colo.1997).

2006A defendant's request for a lesser nonincluded offense instruction "is tantamount to a defendant's consent to an added count being charged against him." People v. Rivera, 186 Colo. 24, 28-29 , 525 P.2d 431, 434 (1974); accord People v. Garcia, 940 P.2d 357, 361 (Colo.1997).

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 (3)

CaseCitedYears
People v. Bartowsheski green
colo · 1983
2 sentences

2018A court abuses its discretion when its decision is 19 “manifestly arbitrary, unreasonable, or unfair.” People v. Ibarra, 849 P.2d 33, 38 (Colo. 1993). ¶ 45 A defendant is entitled to a lesser nonincluded offense instruction as part of his defense theory if the evidence provides a rational basis to support a “verdict acquitting [the defendant] of a greater offense . . . and convicting [the defendant] of the lesser offense.” People v. Trujillo, 83 P.3d 642, 645 (Colo. 2004) (quoting Bartowsheski, 661 P.2d at 242 ).

2018A court abuses its discretion when its decision is 19 “manifestly arbitrary, unreasonable, or unfair.” People v. Ibarra, 849 P.2d 33, 38 (Colo. 1993). ¶ 45 A defendant is entitled to a lesser nonincluded offense instruction as part of his defense theory if the evidence provides a rational basis to support a “verdict acquitting [the defendant] of a greater offense . . . and convicting [the defendant] of the lesser offense.” People v. Trujillo, 83 P.3d 642, 645 (Colo. 2004) (quoting Bartowsheski, 661 P.2d at 242 ).

12018–2018
People v. Rubio green
coloctapp · 2009
1 sentence

2013People v. Rubio, 222 P.3d 355 , 361 (Colo.App.2009) ; see also People v. Trujillo, 83 P.3d 642 , 645 (Colo.2004) ; Garcia, 940 P.2d at 361 . ¶ 91 The offense of false reporting occurs when "[a person] makes a report or knowingly causes the transmission of a report to law enforcement authorities of a crime or other incident within their official concern when he knows that it did not occur." § 18-8-111(1)(b).

12013–2013
People v. Isham green
coloctapp · 1995
1 sentence

2006In People v. Isham, 923 P.2d 190 (Colo. App.1995), the division held that the trial court's erroneous disqualification of the defendant's counsel did not require that a later guilty plea be vacated as involuntary because the defendant had acquiesced in representation by replacement counsel.

12006–2006

Where else courts name it

CO 5 (2006–2025) MS 4 (2004–2018)

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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