Julius Garcia v. Krysta Bialozor

CourtColorado Court of Appeals
DecidedMay 26, 2022
Docket21CA0263
StatusPublished

This text of Julius Garcia v. Krysta Bialozor (Julius Garcia v. Krysta Bialozor) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Julius Garcia v. Krysta Bialozor, (Colo. Ct. App. 2022).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY May 26, 2022

2022COA58

No. 21CA0263, Estate of Garcia — Jurisdiction of Courts — Standing; Probate — Effect of Homicide on Intestate Succession, Wills, Trusts, Joint Assets, Life Insurance, and Beneficiary Designations — Slayer Statute

This opinion answers the unresolved questions of whether a

person who has no legal relationship with a decedent’s heirs has

standing to assert a slayer statute claim in the name of the heirs, or

whether a person who could not obtain a financial benefit from the

forfeiture or revocation sections of the statute may assert a slayer

statute claim solely to obtain a judicial determination that the

defendant feloniously killed the decedent. A division of the court of

appeals concludes that a person who has no legal relationship with

the decedent’s heirs lacks standing to assert a claim under the

slayer statute for the heirs’ financial benefit and that a party who

cannot gain financially from the forfeiture or revocation sections of the slayer statute may not bring a claim solely to obtain a judicial

determination that the defendant feloniously killed the decedent. COLORADO COURT OF APPEALS 2022COA58

Court of Appeals No. 21CA0263 Alamosa County District Court No. 16PR30038 Honorable Martin A. Gonzales, Judge

In re the Estate of Deborah Gene Garcia, deceased.

Julius Garcia,

Appellant,

v.

Krysta Bialozor, as Personal Representative of the Estate of Deborah Gene Garcia, and Diana Strong,

Appellees.

JUDGMENT AFFIRMED IN PART AND REVERSED IN PART

Division III Opinion by JUDGE LIPINSKY Gomez and Davidson*, JJ., concur

Announced May 26, 2022

Erich Schwiesow, P.C., Erich Schwiesow, Alamosa, Colorado, for Appellant

Staggs Morris, P.C., Ernest Staggs, Denver, Colorado, for Appellee Krysta Bialozor

Hutchinson Black & Cook, LLC, John C. Clune, Meghan C. Hungate, Boulder, Colorado, for Appellee Diana Strong

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2021. ¶1 Nearly a century ago, Colorado enacted a “slayer statute” to

bar felonious killers from gaining a financial benefit from the killing.

Yet, until today, no published Colorado case has considered

whether a person who has no legal relationship with a decedent’s

heirs has standing to assert a slayer statute claim in the name of

the heirs, or whether a person who could not obtain a financial

benefit from the forfeiture or revocation sections of the statute may

assert a slayer statute claim solely to obtain a judicial

determination that the defendant feloniously killed the decedent.

¶2 We hold that a person who has no legal relationship with the

decedent’s heirs lacks standing to assert a claim under the slayer

statute for the heirs’ financial benefit. We further hold that a party

who cannot gain financially from the forfeiture or revocation

sections of the slayer statute may not bring a claim solely to obtain

a judicial determination that the defendant feloniously killed the

decedent.

I. Background

¶3 Deborah Gene Garcia (the decedent) was thirty-four years old

at the time of her death. Her husband, Julius Garcia (father),

reported that he found the decedent “face down” in bed and

1 unresponsive several hours after they had engaged in “kinky sex,”

during which her hands were tied to the bed.

¶4 The decedent did not leave a will. She was survived by father

and their children, Krysta Bialozor and A.G. (the children). (We

refer to A.G. by his initials because, unlike Bialozor, he was a minor

when this case was filed.) Father was the decedent’s sole heir. The

children lived with father following their mother’s death.

¶5 The report of an autopsy performed the day after the

decedent’s death noted evidence supporting a conclusion that she

had died of terminal cardiac arrhythmia resulting from an existing

heart condition.

¶6 Twelve years later, the decedent’s sister, Diana Strong,

obtained a second opinion regarding the cause of the decedent’s

death. After analyzing tissue samples from the decedent’s body and

reviewing other information, a pathologist concluded that the

decedent’s death was not the result of cardiac arrhythmia but,

rather, of pulmonary edema. The pathologist said that causes of

pulmonary edema include “intoxication, mechanical asphyxiation,

smothering, cho[]king, neck compression using ligature, . . . and

2 hyper/hypothermia.” The pathologist reported that these causes of

pulmonary edema needed to be “further examined and considered.”

¶7 Armed with the pathologist’s report, Pete DeHerrera, the

decedent’s father, sued father under the slayer statute. DeHerrera

sought a court order that included

(1) a determination under the slayer statute that father

feloniously caused the decedent’s death;

(2) a determination under the slayer statute that the

children are the decedent’s sole heirs; and

(3) a judgment directing father to “forfeit his rights to all

assets belonging to or in which Decedent had an interest,

and in which he was named as a beneficiary or received

benefits under the statutes and governing instruments,”

and to “account for and disgorge to the [children] all

proceeds from their sale and transfer.”

¶8 Bialozor was an adult and A.G. was a minor when DeHerrera

filed the petition. At the time, the children were not parties to the

case.

¶9 Several weeks after DeHerrera filed the petition, Bialozor,

through counsel, filed an objection to the petition. In her objection,

3 Bialozor sought dismissal of the petition, including the claims that

DeHerrera asserted on her behalf.

¶ 10 Because A.G. was a minor at the time, the court appointed a

guardian ad litem (GAL) for him. The GAL recommended that the

court dismiss the case, “as dismissal of this action would be in

[A.G.]’s best interest.”

¶ 11 Strong later joined the case as co-petitioner, and after

DeHerrera was dismissed from the case, she became the sole

petitioner.

¶ 12 Early in the case, father filed several motions, including a

motion to dismiss on the grounds that (1) DeHerrera and Strong

lacked standing to bring the slayer statute claims asserted in the

petition and (2) their claims were barred by the statute of

limitations. The court denied the motions.

¶ 13 After nearly four years of litigation, father made an offer of

settlement in the amount of $500,000 to the children and Strong

pursuant to section 13-17-202(1)(a)(II), C.R.S. 2021. The children

accepted the offer. Strong accepted the offer conditionally in

satisfaction of the “monetary claim” in the petition — the forfeiture

claim asserted in the children’s interest. But she said that father’s

4 offer did not address her “non-monetary claim” — her individual

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Julius Garcia v. Krysta Bialozor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/julius-garcia-v-krysta-bialozor-coloctapp-2022.