Peo v. Becker

Colorado Court of Appeals·Decided July 2, 2026·No. 25CA0627·Unpublished

Opinion

25CA0627 Peo v Becker 07-02-2026 COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0627 Larimer County District Court No. 00CR206 Honorable Joseph D. Findley, Judge

The People of the State of Colorado, Plaintiff-Appellee, v. Joel Howard Becker, Defendant-Appellant.

ORDER AFFIRMED

Division V

Opinion by JUSTICE MARTINEZ* Yun and Schutz, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e)

Announced July 2, 2026

Philip J. Weiser, Attorney General, Paul Koehler, Senior Counsel, Denver, Colorado, for Plaintiff-Appellee

Joel Howard Becker, Pro Se

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2025.

¶1 Defendant, Joel Howard Becker, appeals the postconviction court’s order denying his Crim. P. 35(c) motion for postconviction relief. We affirm.

I. Background

¶2 Becker pleaded guilty to first degree sexual assault and second degree burglary. He was sentenced to the custody of the Department of Corrections (DOC) for an indeterminate term of forty-eight years to life for the sexual assault and a consecutive, determinate term of twelve years for the burglary. A division of this court affirmed the sentences. See People v. Becker, (Colo. App. No. 01CA0151, May 23, 2002) (not published pursuant to C.A.R. 35(f)). The mandate issued in October 2002.

¶3 Years later, the prosecution gave Becker written notice of potential impeachment information regarding a Colorado Bureau of Investigations (CBI) forensic scientist endorsed as a trial witness in his case. The notice stated that “the District Attorney ha[d] NOT been advised by [the] CBI that in [Becker’s] case any anomalies were found in [the scientist’s] work product,” but provided the information pursuant to Colo. RPC 3.8(d) because it “would affect a defendant’s decision about whether to accept a plea disposition.”

The notice indicated that it would be accompanied by a CBI internal affairs report.

¶4 In February 2025, Becker filed a Crim. P. 35(c) motion challenging the validity of his guilty plea. Liberally construing the motion, we determine that he effectively asserted that, because he had no recollection of the underlying incident, his decision to plead guilty was based on DNA evidence linking him to the sexual assault — a connection he now claims is undermined by the new impeachment information. Becker also alleged that the prosecution failed to provide him with the CBI internal affairs report and that he needs the report and a hearing to substantiate his claim. Additionally, Becker argued that his plea counsel was ineffective for misadvising him regarding his parole eligibility and his sentencing exposure if convicted after a trial. Lastly, Becker acknowledged that his motion was untimely but argued that the recently discovered impeachment information constituted justifiable excuse or excusable neglect for the untimely filing.

¶5 In March 2025, the postconviction court summarily denied Becker’s motion, finding that he had not established any exception

to the timeliness procedural bar and had provided no evidence of anomalies in the forensic scientist’s work done on his case.

II. Legal Authority and Standard of Review

¶6 “[A] challenge to a conviction based on a guilty plea is usually limited to whether the plea was knowing, voluntary, and intelligent.” Sanchez-Martinez v. People, 250 P.3d 1248, 1255 (Colo. 2011). As relevant here, a defendant can challenge the validity of their guilty plea based on newly discovered evidence, see People v. Schneider, 25 P.3d 755, 761-62 (Colo. 2001), or allegations of ineffective assistance of counsel, see People v. Stovall, 2012 COA 7M, ¶ 13.

¶7 A challenge to the validity of a defendant’s plea is properly brought under Crim. P. 35(c). People v. Rockwell, 125 P.3d 410, 414 (Colo. 2005). A defendant need not set forth the evidentiary support for their allegations in a Crim. P. 35 motion but instead need only assert facts that if true would provide a basis for relief. White v. Denv. Dist. Ct., 766 P.2d 632, 635 (Colo. 1988). A Crim. P. 35(c) motion for postconviction relief may be denied without an evidentiary hearing only where the motion, files, and record clearly

establish that the defendant’s allegations are without merit and do not warrant relief. Ardolino v. People, 69 P.3d 73, 77 (Colo. 2003).

¶8 Further, a defendant must file a Crim. P. 35(c) motion within three years of their conviction for an offense other than a class 1 felony. § 16-5-402(1), C.R.S. 2025; Crim. P. 35(c)(3)(I). As relevant here, a conviction becomes final when the mandate is issued following a direct appeal. People v. Prendergast, 2024 COA 127,

¶ 28.

¶9 But a postconviction claim shall be excluded from the three-year time limitation period if a court finds that the “failure to seek relief within the applicable time period was the result of circumstances amounting to justifiable excuse or excusable neglect.” § 16-5-402(2)(d). Newly discovered evidence can constitute justifiable excuse or excusable neglect for an untimely filed motion. People v. Clouse, 74 P.3d 336, 340 (Colo. App. 2002).

¶ 10 We review de novo the summary denial of a Crim. P. 35(c) motion. People v. Cali, 2020 CO 20, ¶ 14. Also, “[w]hether a defendant has demonstrated justifiable excuse or excusable neglect is a question of fact to be resolved by the trial court.” People v. Shepherd, 43 P.3d 693, 698 (Colo. App. 2001). “If the record

supports the trial court’s findings, we will not disturb them on appeal.” Id.

III. Analysis

¶ 11 We conclude that the postconviction court did not err by denying Becker’s Crim. P. 35(c) motion. See People v. Hamm, 2019 COA 90, ¶ 23 (“[W]e will affirm a district court’s denial of a Rule 35 motion on any ground supported by the record . . . .”); see also People v. Hartkemeyer, 843 P.2d 92, 92 (Colo. App. 1992) (a court’s failure to make findings of fact or conclusions of law in denying a Crim. P. 35(c) motion does not require reversal if the error was harmless).

¶ 12 First, regarding justifiable excuse or excusable neglect for his ineffective assistance of counsel claims, Becker baldly asserted that he could not have previously raised his ineffective assistance claims without the new impeachment information. Because he does not adequately explain how this information related to the sufficiency of counsel’s plea advisements, we conclude that Becker failed to demonstrate that his delay in asserting the ineffective assistance claims was due to justifiable excuse or excusable neglect. See Clouse, 74 P.3d at 340 (“A defendant must allege in a Crim. P. 35

motion facts that, if true, would establish justifiable excuse or excusable neglect for a belated filing.”); see also People v. Houser, 2020 COA 128, ¶ 24 (we will not consider a bald legal proposition presented without argument or development).

¶ 13 Notably, Becker acknowledged that he knew his counsel’s parole eligibility advisement was purportedly deficient in, at the latest, 2019 when his challenge to the DOC’s parole eligibility calculation was rejected. Yet he did not assert the ineffective assistance claim until nearly six years later. See People v. Wiedemer, 852 P.2d 424, 441 (Colo. 1993) (“In making th[e] determination [regarding the applicability of the justifiable excuse or excusable neglect exception,] we believe it appropriate to consider the circumstances existing throughout the entire period from the inception of the conviction in question.”); see also People v. Cordova, 199 P.3d 1, 4 (Colo. App. 2007) (In determining whether a defendant established justifiable excuse or excusable neglect, the court must consider, among other things, “whether a defendant who had reason to question the constitutionality of a conviction investigated its validity and took advantage of avenues of relief that were available.”).

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