Peo v. Eden

CourtColorado Court of Appeals
DecidedApril 3, 2025
Docket21CA1446
StatusUnpublished

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

Opinion

21CA1446 Peo v Eden 04-03-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 21CA1446 San Miguel County District Court No. 17CR30 Mesa County District Court No. 21CR192 Honorable Keri A. Yoder, Judge Honorable Gretchen B. Larson, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Ika Eden,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division III Opinion by JUDGE TOW Dunn and Taubman*, JJ., concur

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

Philip J. Weiser, Attorney General, Erin K. Grundy, First Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Casey J. Mulligan, Alternate Defense Counsel, Boulder, Colorado, for Defendant-Appellant

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2024. ¶1 Defendant, Ika Eden, appeals the judgment of conviction

entered following jury verdicts finding her guilty of two counts of

child abuse resulting in death. We affirm.

I. Background

¶2 Evidence at trial demonstrated the following.

¶3 Eden was a member of a small religious group, which included

three other adults and two children.1 The two children were the

biological children of one of the other members. With the

permission of a local farmer, Eden and the group settled on the

farmer’s land. In 2017, the leader of the group determined that the

spirits of the two children were impure. The leader banished the

children to a car on the property and forbade the other members to

give the children food or water. The bodies of the children were

discovered after a neighbor contacted the police.

¶4 Eden was charged with two counts of child abuse resulting in

death.2 The jury found her guilty on both counts. The court

1 The group consisted of two additional children, who are the

biological children of the group’s leader and who have no bearing on this proceeding. 2 Other members of the group were also charged in the deaths of

the children and were tried separately.

1 sentenced Eden, on each count, to forty-eight years in the custody

of the Department of Corrections to be served consecutively.

II. Competency to Proceed to Trial

¶5 Eden argues that the trial court erred by determining that she

was competent to proceed to trial. We disagree.

A. Standard of Review

¶6 “We review a trial court’s competency determination for an

abuse of discretion.” People v. Mondragon, 217 P.3d 936, 939 (Colo.

App. 2009). “A trial court abuses its discretion where its decision is

manifestly arbitrary, unreasonable, or unfair or where it applies an

incorrect legal standard.” Id. (citation omitted). Abuse of discretion

is a deferential standard of review that “serves to discourage an

appellate court from second-guessing [a trial court’s decisions]

based on a cold record.” Carrillo v. People, 974 P.2d 478, 486 (Colo.

1999). “To say that a court has discretion in resolving [an] issue

means that it has the power to choose between two or more courses

of action and is therefore not bound in all cases to select one over

the other.” People v. Milton, 732 P.2d 1199, 1207 (Colo. 1987).

¶7 “Subjecting a defendant to trial when [they are] incompetent

violates the defendant’s right to due process.” Mondragon, 217 P.3d

2 at 939. A defendant is “[i]ncompetent to proceed” if, “as a result of

a mental disability . . . , the defendant does not have sufficient

present ability to consult with the defendant’s lawyer with a

reasonable degree of rational understanding in order to assist in the

defense.” § 16-8.5-101(12), C.R.S. 2024. Alternatively, a defendant

is incompetent to proceed, when “as a result of a mental

disability . . . , the defendant does not have a rational and factual

understanding of the criminal proceedings.” Id. A mental disability

“means a substantial disorder of thought, mood, perception, or

cognitive ability that results in marked functional disability,

significantly interfering with adaptive behavior.” § 16-8.5-101(15).

¶8 Once a defendant is deemed incompetent, “the party asserting

that the defendant is competent has the burden of proof by a

preponderance of the evidence.” § 16-8.5-113(6), C.R.S. 2024.

Upon the party’s timely request, the court must hold a restoration

hearing at which “the court shall determine whether the defendant

is restored to competency.” § 16-8.5-113(5)-(6). To make a proper

competency determination, the court must decide whether the

defendant has “both a factual understanding and cognitive ability

and perceptions and understandings that are rational and

3 grounded in reality.” Mondragon, 217 P.3d at 941. “Thus, a

defendant’s factual understanding of the proceedings[;] proper

orientation as to time, place, and person[;] and [their] ability to

furnish accurately information as to [their] past history and the

events at issue are not alone sufficient to establish the defendant’s

competence.” Id. at 940.

B. Additional Background

¶9 In March 2018, shortly after Eden’s arraignment, defense

counsel requested the trial court order Eden to undergo a

competency evaluation. Dr. Dawn Dawson conducted the

examination and found that Eden did “not have a mental disability”

and that she was, at that time, “competent to proceed to trial.”

After a hearing, without objection from either party, the trial court

found Eden competent to proceed.

¶ 10 A few months later, the prosecution requested another

competency evaluation based on writings discovered in Eden’s jail

cell. Those writings included assertions about her spirit, the spirits

of the children, and the spirits of the judge and lawyers involved in

her case. For example, Eden claimed that she was “the first of

[Yahweh’s] creation” and that she was “6,384,964 years old.” She

4 also wrote that the children placed in the car were “the two Headed

dragon,” that “in one of their reincarnation[s,] . . . had randomly

kidnapped eight (8) children for the sole pleasure of watching [them]

die of hunger and starvation” and that their death in the car was

“judgement [sic] that was meted out to their consciousness.”

¶ 11 The trial court granted the prosecution’s request and

Dr. Dawson again evaluated Eden. This time, Dr. Dawson found

that “Eden has a mental illness,” that “her writings are delusional,”

and that she portrayed a “grandiose tone that [indicates] a possible

mood disorder.” Dr. Dawson concluded that Eden was incompetent

to proceed to adjudication.

¶ 12 Eden was committed to the Colorado Mental Health Institute

in Pueblo (CMHIP)3 for restoration treatment, where she underwent

five competency evaluations with Dr. Katherine Reis over the course

of fourteen months. In each evaluation, Dr. Reis deemed Eden

incompetent to proceed and diagnosed her with “Rule/Out

Delusional Disorder,” which Dr. Reis explained meant she was

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Related

Von Moltke v. Gillies
332 U.S. 708 (Supreme Court, 1948)
People v. Milton
732 P.2d 1199 (Supreme Court of Colorado, 1987)
People v. Wright
648 P.2d 665 (Supreme Court of Colorado, 1982)
People v. Romero
694 P.2d 1256 (Supreme Court of Colorado, 1985)
People v. Morino
743 P.2d 49 (Colorado Court of Appeals, 1987)
People v. Barber
799 P.2d 936 (Supreme Court of Colorado, 1990)
People v. Mondragon
217 P.3d 936 (Colorado Court of Appeals, 2009)
People v. Davis
2015 CO 36 (Supreme Court of Colorado, 2015)
Coke v. People
2020 CO 28 (Supreme Court of Colorado, 2020)
People v. Smith
716 P.2d 1115 (Supreme Court of Colorado, 1986)
People v. Arguello
772 P.2d 87 (Supreme Court of Colorado, 1989)
Carrillo v. People
974 P.2d 478 (Supreme Court of Colorado, 1999)
People v. Johnson
2015 COA 54 (Colorado Court of Appeals, 2015)

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Peo v. Eden, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-v-eden-coloctapp-2025.