Peo v. Eddington

CourtColorado Court of Appeals
DecidedFebruary 19, 2026
Docket23CA1855
StatusUnpublished

This text of Peo v. Eddington (Peo v. Eddington) 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. Eddington, (Colo. Ct. App. 2026).

Opinion

23CA1855 Peo v Eddington 02-19-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 23CA1855 Douglas County District Court No. 19CR479 Honorable Ryan J. Stuart, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Harlan Nelson Eddington,

Defendant-Appellant.

SENTENCE AND ORDER AFFIRMED

Division I Opinion by JUDGE LUM J. Jones and Meirink, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced February 19, 2026

Philip J. Weiser, Attorney General, Brittany Limes Zehner, Senior Assistant Attorney General and Assistant Solicitor General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Kevin M. Whitfield, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Harlan Nelson Eddington, pleaded guilty to two

crimes involving the death of his romantic partner. He appeals his

sentence and the order imposing restitution.

I. Background

¶2 Eddington and his romantic partner, Molly Sadler, got into a

verbal dispute while Eddington was driving on Highway 67.

Eddington suddenly turned his doorless Jeep into oncoming traffic,

and a car collided with the passenger side of the vehicle, where

Sadler was sitting. Eddington got out of the vehicle immediately

after the collision and ran from the scene. Police apprehended him

on foot several hours later and noted that he appeared to be under

the influence of alcohol. Sadler was taken to the hospital and died

the next day due to injuries sustained in the crash. At the time of

the collision, a protection order prohibited Eddington from

interacting with Sadler and from using alcohol or controlled

substances.

¶3 Eddington pleaded guilty to leaving the scene of an accident in

violation of section 42-4-1601(1), (2)(c), C.R.S. 2025, and vehicular

homicide in violation of section 18-3-106(1)(a), C.R.S. 2025. The

plea agreement contained a stipulated sentencing range of four to

1 eighteen years in the custody of the Department of Corrections

(DOC). The sentencing court imposed an eighteen-year sentence.

The court also ordered Eddington to pay $5,487 in restitution to

compensate the Crime Victim Compensation Board (CVCB)1 for

payments it made to Sadler’s family for her funeral and burial

expenses.

¶4 Eddington now argues that (1) the sentencing judge was

biased against him, and (2) the sentencing judge erred by ordering

him to pay the full amount of restitution to the CVCB when Sadler’s

family had also received donations from a GoFundMe campaign.

We address each contention in turn.

1 The terms “Crime Victim Compensation Board” and “Crime Victim

Compensation Fund” are used interchangeably throughout the record in this case. Prior opinions from this court discussing restitution use both “board” and “fund” and also refer to a “Crime Victim Compensation Program.” As best we can discern, all these terms refer to an entity that is a “victim” under the restitution statute because it is a “victim compensation board that has paid a victim compensation claim.” § 18-1.3-602(4)(a)(IV), C.R.S. 2025. Thus, for consistency, we use the term “CVCB” throughout this opinion.

2 II. Sentencing

¶5 Eddington argues that his eighteen-year sentence (the

maximum possible sentence under the plea agreement) is the result

of actual bias on the part of the sentencing judge. We disagree.

A. Additional Background

¶6 At the sentencing hearing, the court heard testimony from

eight witnesses for the State, one mitigation witness for the defense,

and from Eddington. After the testimony and while sentencing

Eddington, the judge made the following remarks:

• People who never met Sadler “will never get to see this

beautiful face. People who never met her, like myself,

will never get to hear this beautiful laugh. We’ll never get

a kiss on the lips and a hug when I meet her. And that’s

a loss. Everyone’s a victim.”

• “You killed [Sadler] . . . And like what your witness said,

it is all your fault.”

• Sadler “suffered a year of abuse under the hands of Mr.

Eddington.”

• The most haunting part of the case is Sadler’s words that

“were overheard by a witness about Mr. Eddington killing

3 her, and Mr. Eddington’s father warning her. [Sadler]

knew she was going to die in the hands of Mr. Eddington.

She didn’t know when; she didn’t know how, but I think

she knew.”

B. Standard of Review and Applicable Law

¶7 Because Eddington didn’t move to disqualify the sentencing

judge, our review is limited to whether the judge displayed “actual

bias.” People v. Dobler, 2015 COA 25, ¶¶ 6-7. We review claims of

actual bias de novo. People v. Jennings, 2021 COA 112, ¶¶ 27-28.

¶8 Actual bias is “bias or prejudice that in all probability will

prevent [a judge] from dealing fairly with a party.” People v. Julien,

47 P.3d 1194, 1197 (Colo. 2002). A defendant arguing that the trial

judge was biased “must establish that the judge had a substantial

bent of mind against him.” People v. Drake, 748 P.2d 1237, 1249

(Colo. 1988). Mere speculative statements are not enough, and the

record must clearly establish such bias. Id.

¶9 In Colorado, “[t]he general rule of law is that what a judge

learns in his judicial capacity is a proper basis for judicial

observations, and that the use of such information is not the kind

of matter that results in disqualification.” Smith v. Dist. Ct., 629

4 P.2d 1055, 1057 (Colo. 1981). “[O]pinions formed by the judge on

the basis of facts introduced or events occurring in the course of the

current proceedings . . . do not constitute a basis for a bias or

partiality motion unless they display a deep-seated favoritism or

antagonism that would make fair judgment impossible.” Dobler,

¶ 25 (quoting Liteky v. United States, 510 U.S. 540, 555 (1994)).

C. Analysis

¶ 10 Eddington argues that the sentencing judge was biased for two

reasons. First, he argues that the sentencing judge exhibited actual

bias by “counting himself as a victim” and by telling Eddington that

Sadler’s death was “all [Eddington’s] fault.” Second, Eddington

contends that the judge based his opinions about Eddington (and,

thus, the sentence) on facts that weren’t in the record. We address

each argument in turn.

1. “Victim” and “Fault” Remarks

¶ 11 Eddington argues that the sentencing judge exhibited actual

bias when he said, “We’ll never get a kiss on the lips and a hug

when I meet [Sadler]. And that’s a loss. Everyone’s a victim.” He

also contends the judge exhibited bias when he admonished

Eddington by telling him, “[I]t is all your fault.” We disagree.

5 ¶ 12 Read in context, the record reveals that the judge’s

observation that “[p]eople who never met [Sadler], like myself,”

would never receive a “kiss on the lips and a hug” related directly to

the following testimony from Sadler’s niece:

I loved introducing new people to her, without warning, and she would go in for that kiss and big old hug and surprise them.

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Related

Liteky v. United States
510 U.S. 540 (Supreme Court, 1994)
Saucerman v. Saucerman
461 P.2d 18 (Supreme Court of Colorado, 1969)
People v. Drake
748 P.2d 1237 (Supreme Court of Colorado, 1988)
People v. Julien
47 P.3d 1194 (Supreme Court of Colorado, 2002)
People v. Lassek
122 P.3d 1029 (Colorado Court of Appeals, 2005)
Clarks State Bank v. De Witt
1931 OK 681 (Supreme Court of Oklahoma, 1931)
People v. Stanley
2017 COA 121 (Colorado Court of Appeals, 2017)
Cowen v. People
2018 CO 96 (Supreme Court of Colorado, 2018)
McCoy v. People
2019 CO 44 (Supreme Court of Colorado, 2019)
v. Gregory
2019 COA 184 (Colorado Court of Appeals, 2019)
v. People
2020 CO 58 (Supreme Court of Colorado, 2020)
v. Jennings
2021 COA 112 (Colorado Court of Appeals, 2021)
People v. Schupper
2014 COA 80M (Colorado Court of Appeals, 2014)
People v. Dobler
2015 COA 25 (Colorado Court of Appeals, 2015)
The People of the State of Colorado v. Benjamin Weeks
2021 CO 75 (Supreme Court of Colorado, 2021)

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Bluebook (online)
Peo v. Eddington, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-v-eddington-coloctapp-2026.