Peo v. Dent

CourtColorado Court of Appeals
DecidedJuly 3, 2025
Docket22CA1266
StatusUnpublished

This text of Peo v. Dent (Peo v. Dent) 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
Peo v. Dent, (Colo. Ct. App. 2025).

Opinion

22CA1266 Peo v Dent 07-03-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 22CA1266 Arapahoe County District Court No. 21CR268 Honorable Elizabeth Weishaupl, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Phillip Michael Dent,

Defendant-Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division V Opinion by JUDGE GROVE Welling and Johnson, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced July 3, 2025

Philip J. Weiser, Attorney General, Trina K. Kissel, Senior Assistant Attorney General and Assistant Solicitor General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Rachel Z. Geiman, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Phillip Michael Dent, appeals the judgment of

conviction entered upon a jury verdict finding him guilty of

aggravated motor vehicle theft and arson. We reverse and remand

for further proceedings consistent with this opinion.

I. Background

¶2 The prosecution presented evidence from which the jury could

reasonably find the following facts.

¶3 On January 28, 2021, Dent stole Cindy Turco’s minivan while

she was at an automatic car wash in Littleton. Security footage

showed a man later identified as Dent approach Turco’s driver side

door while the car wash was running and demand that she get out.

Turco resisted, and Dent tried to pull her out of the van, grabbing

her by the neck and biting her wrist in the process. He eventually

succeeded, and after “throwing [Turco] out of the car,” Dent got in

and drove away.

¶4 Three days later, Turco’s van was found destroyed in a parking

lot in Lakewood with its original South Dakota plates removed.

Investigators determined it had been intentionally set on fire.

¶5 A police detective issued a media bulletin asking for the

public’s help in identifying the carjacking suspect. A former

1 roommate of Dent’s called the detective and suggested Dent was

responsible. She provided the detective with incriminating text

messages from Dent in which he admitted to stealing a vehicle of

the same make and model as Turco’s at a car wash.

¶6 To locate Dent, police requested a search warrant for records

maintained by his wireless phone service provider. A district court

judge approved the warrant application, and T-Mobile USA (T-

Mobile) subsequently turned over records within the scope of the

warrant, including, among other things, GPS locations, text

messages, and call data collected during the few weeks before and

after the carjacking. Some of the records implicated Dent in the

charged offenses.

¶7 Three months after the motions deadline had passed, and

after the final pretrial conference, Dent filed a motion to suppress

the records produced by T-Mobile pursuant to the search warrant.

As relevant here, he argued that the warrant was overbroad and

that “no probable cause was established to believe that any criminal

offense occurred and/or that any material information would be

produced from records” generated in the few weeks before the

offense. In its response, the prosecution maintained that the

2 warrant was valid but, even if it was not, that the good faith

exception to the exclusionary rule applied. The court addressed the

motion from the bench on the morning of the first day of trial.

Without taking evidence, the court ruled that the warrant

established probable cause for the search and was sufficiently

particular. In the alternative, the court found that the good faith

exception to the exclusionary rule would apply in the event that the

warrant was deemed invalid.

¶8 At trial, Dent admitted that he had committed robbery and

third degree assault, and he does not appeal those convictions (or

his conviction on a burglary charge arising from events after the

theft of the van). He does, however, challenge his convictions for

aggravated motor vehicle theft and second degree arson, arguing

that the court erroneously denied the suppression motion and

committed several evidentiary errors at trial. He also challenges

$98.35 of the $2,125.33 that the trial court awarded in restitution.

¶9 We conclude that the trial court reversibly erred by admitting

records provided by T-Mobile without establishing either that they

were machine generated (and thus not hearsay) or that they

qualified as business records (and were thus admissible under CRE

3 803(6)). However, because it will likely arise in the event of a

retrial, we first consider Dent’s challenge to the trial court’s

suppression ruling. Finally, because we leave three of Dent’s

convictions undisturbed, we address his challenge to the court’s

restitution award. We do not reach Dent’s remaining evidentiary

arguments because it is unclear whether they will arise again in the

event that he is retried.

II. Suppression Motion

¶ 10 Dent contends that the trial court erroneously denied his

motion to suppress the evidence obtained from the T-Mobile search

warrant because the warrant was overbroad and lacked probable

cause. We disagree.

A. Standard of Review

¶ 11 “A trial court’s ruling on a motion to suppress presents a

mixed question of fact and law.” Pettigrew v. People, 2022 CO 2,

¶ 49. “We therefore ‘defer to the trial court’s findings of fact that

are supported by the record, but we assess the legal effect of those

facts de novo.’” Id. (quoting People v. Hyde, 2017 CO 24, ¶ 9). We

also review de novo whether a “warrant and supporting affidavit

4 complied with the Fourth Amendment’s particularity requirement.”

Id.

¶ 12 “We review preserved trial errors of constitutional dimension,

including the admission of evidence obtained in violation of the

Fourth Amendment, for constitutional harmless error.” Id. at ¶ 50.

“Under this standard, reversal is required unless the reviewing

court can conclude that the error was harmless beyond a

reasonable doubt.” Id. “In other words, we will reverse if ‘there is a

reasonable possibility that the [error] might have contributed to the

conviction.’” Id. (alteration in original) (quoting Hagos v. People,

2012 CO 63, ¶ 11).

B. Applicable Law

¶ 13 “The Fourth Amendment to the United States Constitution . . .

prohibit[s] the issuance of a search warrant except upon probable

cause supported by oath or affirmation particularly describing the

place to be searched and the things to be seized.” People v.

Rodriguez-Ortiz, 2025 COA 61, ¶ 21. “To prevent general,

exploratory searches, the Fourth Amendment requires ‘a “particular

description” of the things to be seized.’” People v. Coke, 2020 CO

28, ¶ 34 (quoting Andresen v. Maryland, 427 U.S. 463, 480 (1976)).

5 Courts consider “whether the description in a warrant is sufficiently

particular that it enables the executing officer to reasonably

ascertain and identify the things authorized to be seized.” People v.

Roccaforte, 919 P.2d 799, 803 (Colo. 1996). Likewise, to establish

probable cause, a warrant affidavit must “allege facts sufficient to

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