Colorado Revised Statutes
Colo. Rev. Stat. § 18-4-414 (2024)
Evidence of value
✓ C.R.S. 2024: the 2025 and 2026 sessions are not included
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(1) For purposes of this part 4, when theft occurs from a store, evidence of the retail value of the thing involved shall be prima facie evidence of the value of the thing involved. Evidence offered to prove retail value may include, but shall not be limited to, affixed labels and tags, signs, shelf tags, and notices.
(2) For the purposes of this part 4, in all cases where theft occurs, evidence of the value of the thing involved may be established through the sale price of other similar property and may include, but shall not be limited to, testimony regarding affixed labels and tags, signs, shelf tags, and notices tending to indicate the price of the thing involved. Hearsay evidence shall not be excluded in determining the value of the thing involved.
Source: L. 85: Entire section added, p. 668, § 1, effective July 1. L. 88: Entire section amended, p. 713, § 20, effective July 1.
Notes of Decisions
Cited in 10
cases (2 in the last 5 years), 1989–2026 · leading case: v. Vidauri, 2019 COA 140.
v. Vidauri, 2019 COA 140. “¶ 17 Although section 18-4-414, C.R.S. 2018, addresses proving retail value, neither the theft statute nor any Colorado case explains how the prosecution proves the value of public assistance benefits obtained as a result of a defendant’s deceit.”
People v. Thornton, 251 P.3d 1147 (Colo. Ct. App. 2010). “We hold that the Kelley Blue Book may be admitted as proof of value under section 18-4-414(2), C.R.S.2010, and CRE 803(17), without the need for expert testimony to substantiate the Blue Book's valuation.”
People v. Pearman, 209 P.3d 1144 (Colo. Ct. App. 2008). “On appeal, defendant argues that "[bloth Schmidt and § 18-4-414 require the price tags or copies of the price tags to be entered into evidence to establish the value of an item.”
People v. Reed, 2013 COA 113, 338 P.3d 364. “T45 Over Reed's objection, the trial court-relying on section 18-4-414(2), which allows hearsay testimony of the sale price of a stolen object to establish its value-allowed the co-owner of the victim's car to testify about the estimated cost to repair the car 3 {46 Reed…”
People v. Bornman, 953 P.2d 952 (Colo. Ct. App. 1997). “Another issue that may arise on retrial lies in defendant’s contention that he was denied his constitutional right to confrontation by the admission of hearsay testimony on the issue of the value of the stolen property, as provided for in § 18-4-414(2), C.R.S. 1997. We conclude,…”
People v. Schmidt, 928 P.2d 805 (Colo. Ct. App. 1996). “Defendant further asserts that the prosecution was required to produce a declarant — someone knowledgeable of the items’ values — and that the General Assembly’s attempt to circumvent this evidentiary step in § 18-4-414 is unconstitutional. We disagree.”
People v. Velarde, 790 P.2d 903 (Colo. Ct. App. 1989). “Section 18-4-414, C.R.S. (1986 Repl.Vol. 8B), amended effective July 1, 1988, Colo.”
People v. Jaeb, 434 P.3d 785 (Colo. Ct. App. 2018). “Business Records Exception ¶ 15 We conclude that this affidavit was not admissible as a business record under the hearsay exception.”
Peo v. Smith, No. 23CA1797 (Colo. Ct. App. Apr. 2, 2026). “4 3 The Facebook Marketplace evidence was arguably admissible under section 18-4-414. But we don’t need to decide that issue.”
People v. Bolden, 590 P.3d 308 (Colo. Ct. App. 2026). “1996) (explaining that section 18-4-414 “allows an accused to rebut the presumption of value” by calling a witness “to establish a value other than that specified on the price tag”).”
Colo. Rev. Stat. § 18-4-414(1): 3 cases
People v. Pearman, 209 P.3d 1144 (Colo. Ct. App. 2008). “On appeal, defendant argues that "[bloth Schmidt and § 18-4-414 require the price tags or copies of the price tags to be entered into evidence to establish the value of an item.”
People v. Jaeb, 434 P.3d 785 (Colo. Ct. App. 2018). “Business Records Exception ¶ 15 We conclude that this affidavit was not admissible as a business record under the hearsay exception.”
People v. Bolden, 590 P.3d 308 (Colo. Ct. App. 2026). “1996) (explaining that section 18-4-414 “allows an accused to rebut the presumption of value” by calling a witness “to establish a value other than that specified on the price tag”).”
Colo. Rev. Stat. § 18-4-414(2): 6 cases
People v. Thornton, 251 P.3d 1147 (Colo. Ct. App. 2010). “We hold that the Kelley Blue Book may be admitted as proof of value under section 18-4-414(2), C.R.S.2010, and CRE 803(17), without the need for expert testimony to substantiate the Blue Book's valuation.”
People v. Reed, 2013 COA 113, 338 P.3d 364. “T45 Over Reed's objection, the trial court-relying on section 18-4-414(2), which allows hearsay testimony of the sale price of a stolen object to establish its value-allowed the co-owner of the victim's car to testify about the estimated cost to repair the car 3 {46 Reed…”
People v. Bornman, 953 P.2d 952 (Colo. Ct. App. 1997). “Another issue that may arise on retrial lies in defendant’s contention that he was denied his constitutional right to confrontation by the admission of hearsay testimony on the issue of the value of the stolen property, as provided for in § 18-4-414(2), C.R.S. 1997. We conclude,…”
People v. Pearman, 209 P.3d 1144 (Colo. Ct. App. 2008). “On appeal, defendant argues that "[bloth Schmidt and § 18-4-414 require the price tags or copies of the price tags to be entered into evidence to establish the value of an item.”
People v. Jaeb, 434 P.3d 785 (Colo. Ct. App. 2018). “Business Records Exception ¶ 15 We conclude that this affidavit was not admissible as a business record under the hearsay exception.”
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