Colorado Revised Statutes

Colo. Rev. Stat. § 16-3-201 (2026)

Arrest by a private person

✓ current as of July 2026
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A person who is not a peace officer may arrest another person when any crime has been or is being committed by the arrested person in the presence of the person making the arrest.

Source: L. 72: R&RE, p. 199, § 1. C.R.S. 1963: § 39-3-201.

Notes of Decisions
Cited in 9 cases, 1978–2012 · leading case: People v. Wolf, 635 P.2d 213 (Colo. 1981).
People v. Wolf, 635 P.2d 213 (Colo. 1981). · cites it 22× “Section 16-3-201, C.R.S.1973 (1978 Repl.Vol.”
People v. Hamilton, 666 P.2d 152 (Colo. 1983). · cites it 4× “The opinion assumes that the Arapahoe County deputy sheriff had no common law authority outside Arapahoe County to arrest a person who was the object of an arrest warrant.”
People v. Vigil, 729 P.2d 360 (Colo. 1986). · cites it 4× “(1986), and were not acting as private citizens under section 16-3-201, 8A C.R.S. (1986), nonetheless, they had the power to arrest persons for a crime committed in their presence.”
People v. Bloom, 577 P.2d 288 (Colo. 1978). · cites it 3× “Section 16-3-201, C.R.S. 1973. If private citizens have the power to arrest persons who commit crimes in their presence, certainly a police officer, outside his territorial jurisdiction, has the same power.”
People v. Joyce, 68 P.3d 521 (Colo. Ct. App. 2002). · cites it 3× “On the other hand, § 18-1-707(7) is part of the article codifying *524 affirmative defenses including, inter alia, the use of physical force.”
People v. Florez, 680 P.2d 219 (Colo. 1984). · cites it 3× “) See section 16-3-201, C.R.S.1973 (1978 Repl.Vol.”
Land v. Hill, 644 P.2d 43 (Colo. Ct. App. 1981). · cites it 2× “2d 234 (1974); § 16-3-201, C.R.S. 1973; Colorado Jury Instructions § 21:10 (2d ed.”
People v. Chirico, 272 P.3d 1170 (Colo. Ct. App. 2012). · cites it 2× “§ 16-3-201, C.R.S. 2011. Just as a peace officer attempting or making an arrest "is justified in using reasonable and appropriate physical force," § 18-1-707(1)(a), C.”
State v. Harding, 508 A.2d 471 (Me. 1986). · cites it 2× “Section 16-3-201, C.R.S.1973 (1978 Repl. Vol.”
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