Colo. Rev. Stat. » Title 18
Colorado Revised Statutes

Colo. Rev. Stat. § 18-8-102 (2026)

Obstructing government operations

✓ current as of July 2026
Find cases: SyfertCases citing this section CO-LEGleg.colorado.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

(1) A person commits obstructing government operations if he intentionally obstructs, impairs, or hinders the performance of a governmental function by a public servant, by using or threatening to use violence, force, or physical interference or obstacle.

(2) It shall be an affirmative defense that:

(a) The obstruction, impairment, or hindrance was of unlawful action by a public servant; or

(b) The obstruction, impairment, or hindrance was of the making of an arrest; or

(c) The obstruction, impairment, or hindrance of a governmental function was by lawful activities in connection with a labor dispute with the government.

(3) Obstructing government operations is a class 2 misdemeanor.

Source: L. 71: R&RE, p. 453, § 1. C.R.S. 1963: § 40-8-102. L. 73: p. 538, § 5. L. 2022:

(3) amended, (HB 22-1229), ch. 68, p. 345, § 27, effective March 1.

Editor's note: Section 47 of chapter 68 (HB 22-1229), Session Laws of Colorado 2022, provides that the act amending subsection (3) is effective March 1, 2022, but the governor did not approve the act until April 7, 2022.

Cross references: For impeding any public official in the lawful performance of his or her duties or activities, see § 18-9-110.

Notes of Decisions
Cited in 32 cases (2 in the last 5 years), 1981–2025 · leading case: Doubleday v. People, 2016 CO 3 (Colo. 2016).
Sort: Relevance Newest Treatment
Doubleday v. People, 2016 CO 3 (Colo. 2016). · cites it 5× “Statutory Analysis { 21 The felony murder statute, section 18-8-102(1)(b), provides, in pertinent part: A person commits the crime of murder in 'the first degree if; .”
People v. Harlan, 8 P.3d 448 (Colo. 2000). · cites it 10× “Harlan eventually was charged with one count of first degree murder after deliberation, in violation of section 18-8-102(1)(a), 6 CRS. (1999); one count of felony murder, in violation of section 18-8-102(1)(b), 6 CRS.”
People v. Grant, 174 P.3d 798 (Colo. Ct. App. 2007). · cites it 3× “Section 18-8-102(1)(a), C.R.S.2006, provides, "A person commits the crime of murder in the first degree if .”
People v. Fuentes, 258 P.3d 320 (Colo. Ct. App. 2011). · cites it 2× “See § 18-8-102(1)(b), C.R.S.2010. That statute provides that a person commits felony murder when anyone causes a death "in the course of .”
People v. Caldwell, 43 P.3d 663 (Colo. Ct. App. 2001). · cites it 3× “Section 18-8-102(1), C.R.S.2000; Gann v. People, supra; People v.”
People v. Gladney, 250 P.3d 762 (Colo. Ct. App. 2010). · cites it 3× “[alfter deliberation and with the intent to cause the death of a person other than himself, he causes the death of that person or another person.”
People v. McBride, 228 P.3d 216 (Colo. Ct. App. 2009). · cites it 2× “§ 18-8-102(1)(a), C.R.S.2009 (emphasis added); see § 18-2-101(1), C.”
People v. Drake, 748 P.2d 1237 (Colo. 1988). · cites it 2× “Richard Owen Drake, the defendant, was found guilty by a jury of murder in the first degree, in violation of section 18-8-102, 8B C.R.S. (1986), in connection with the death of his wife, Regina Drake.”
People v. Stovall, 284 P.3d 151 (Colo. Ct. App. 2012). · cites it 4× “1 21 Section 18-8-102(1)(b) states: A person commits the crime of murder in the first degree if: [[Image here]] (b) Acting either alone or with one or more persons, he or she commits or attempts to commit arson, robbery, burglary, kidnapping, sexual assault as prohibited by…”
People v. Small, 631 P.2d 148 (Colo. 1981). · cites it 3× “The case is a consolidation of two separate appeals brought by the defendant, Charles Raymond Small, as a result of his conviction for first-degree murder in violation of section 18-8-102(1)(b), C.R.S.1978 (1978 Repl.”
People v. Gross, 287 P.3d 105 (Colo. 2012). · cites it 2× “See § 18-8-102(1)(d), C.R.S. (2012). 115 The facts presented by the defendant support a self-defense instruction.”
People v. Childress, 2015 CO 65 (Colo. 2015). · cites it 2× “" § 18-8-102, C.R.S. (2015). Because the "commission" of these two crimes is so different, so too are the requirements for guilt under a complicity theory.”
Show all 32 citing cases →
— Colo. Rev. Stat. § 18-8-102(1) — 5 cases
People v. Caldwell, 43 P.3d 663 (Colo. Ct. App. 2001). “Section 18-8-102(1), C.R.S.2000; Gann v. People, supra; People v.”
Sklar v. Dep't of Health, 798 A.2d 268 (Pa. Commw. Ct. 2002).
People v. Harris, 370 P.3d 231 (Colo. Ct. App. 2015).
Frost v. Med. Man Tech., Inc. (D. Colo. 2025).
Lucero v. City of Aurora (D. Colo. 2025).
— Colo. Rev. Stat. § 18-8-102(1)(a) — 7 cases
People v. Grant, 174 P.3d 798 (Colo. Ct. App. 2007). “Section 18-8-102(1)(a), C.R.S.2006, provides, "A person commits the crime of murder in the first degree if .”
People v. Harlan, 8 P.3d 448 (Colo. 2000). “Harlan eventually was charged with one count of first degree murder after deliberation, in violation of section 18-8-102(1)(a), 6 CRS. (1999); one count of felony murder, in violation of section 18-8-102(1)(b), 6 CRS.”
People v. Gladney, 250 P.3d 762 (Colo. Ct. App. 2010). “[alfter deliberation and with the intent to cause the death of a person other than himself, he causes the death of that person or another person.”
People v. McBride, 228 P.3d 216 (Colo. Ct. App. 2009). “§ 18-8-102(1)(a), C.R.S.2009 (emphasis added); see § 18-2-101(1), C.”
People v. Versteeg, 165 P.3d 760 (Colo. Ct. App. 2007).
— Colo. Rev. Stat. § 18-8-102(1)(b) — 12 cases
Doubleday v. People, 2016 CO 3 (Colo. 2016). “Statutory Analysis { 21 The felony murder statute, section 18-8-102(1)(b), provides, in pertinent part: A person commits the crime of murder in 'the first degree if; .”
People v. Harlan, 8 P.3d 448 (Colo. 2000). “Harlan eventually was charged with one count of first degree murder after deliberation, in violation of section 18-8-102(1)(a), 6 CRS. (1999); one count of felony murder, in violation of section 18-8-102(1)(b), 6 CRS.”
People v. Fuentes, 258 P.3d 320 (Colo. Ct. App. 2011). “See § 18-8-102(1)(b), C.R.S.2010. That statute provides that a person commits felony murder when anyone causes a death "in the course of .”
People v. Stovall, 284 P.3d 151 (Colo. Ct. App. 2012). “1 21 Section 18-8-102(1)(b) states: A person commits the crime of murder in the first degree if: [[Image here]] (b) Acting either alone or with one or more persons, he or she commits or attempts to commit arson, robbery, burglary, kidnapping, sexual assault as prohibited by…”
People v. Small, 631 P.2d 148 (Colo. 1981). “The case is a consolidation of two separate appeals brought by the defendant, Charles Raymond Small, as a result of his conviction for first-degree murder in violation of section 18-8-102(1)(b), C.R.S.1978 (1978 Repl.”
— Colo. Rev. Stat. § 18-8-102(1)(d) — 3 cases
People v. Gross, 287 P.3d 105 (Colo. 2012). “See § 18-8-102(1)(d), C.R.S. (2012). 115 The facts presented by the defendant support a self-defense instruction.”
People v. Lara, 224 P.3d 388 (Colo. Ct. App. 2009).
People v. Alvarado-juarez, 252 P.3d 1135 (Colo. Ct. App. 2010).
— Colo. Rev. Stat. § 18-8-102(4) — 1 case
People v. Wickham, 53 P.3d 691 (Colo. Ct. App. 2001).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.