Peo v. Elhoweris

CourtColorado Court of Appeals
DecidedFebruary 5, 2026
Docket23CA0603
StatusUnpublished

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

Opinion

23CA0603 Peo v Elhoweris 02-05-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 23CA0603 Arapahoe County District Court No. 14CR1984 Honorable Ryan J. Stuart, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Amin Elhoweris,

Defendant-Appellant.

ORDER AFFIRMED

Division III Opinion by JUDGE DUNN Moultrie and Taubman*, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced February 5, 2026

Philip J. Weiser, Attorney General, Austin R. Johnston, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Zobel Law, LLC, Cassandra Zobel, Denver, 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. 2025. ¶1 Amin Elhoweris appeals the postconviction court’s order

denying his Crim. P. 35(c) motion.1 He contends that the court

should have held an evidentiary hearing on his claim that trial

counsel was ineffective by failing to investigate and present an

intoxication defense.2 Because we conclude that Elhoweris did not

sufficiently allege prejudice, we affirm.

I. Background

¶2 For his involvement in a gang-related shooting, a grand jury

indicted Elhoweris on charges of first degree murder, two counts of

attempted first degree murder (after deliberation and extreme

indifference), and conspiracy to commit first degree murder.

1 Because the record is unclear as to whether Elhoweris’s name is

spelled with a hyphen (El-Howeris), we adopt the spelling used by both parties in this appeal.

2 As we understand it, Elhoweris appeals the denial of his first

postconviction claim, which alleged that defense counsel failed to adequately investigate and present evidence of both voluntary and involuntary intoxication. The jury, however, considered and rejected voluntary intoxication. Thus, although Elhoweris refers simply to “intoxication defense” in his briefing, because he doesn’t develop any argument specific to voluntary intoxication, we construe “intoxication defense” as referring only to involuntary intoxication.

1 ¶3 Early in the case, Elhoweris told his trial counsel that he had

taken four pills of Percocet (a pain medication) over a two-day

period before the shooting and had also smoked marijuana and

drunk alcohol on the day of the shooting. Trial counsel obtained

some medical records and went back and forth as to whether to

present an expert witness on involuntary intoxication. Though trial

counsel consulted with an expert witness, he ultimately did not call

an expert witness to testify about involuntary intoxication.

¶4 At the close of evidence, trial counsel asked for an involuntary

intoxication instruction, but the court declined because there was

“no independent evidence of involuntary intoxication.” The court

agreed, however, to instruct the jury on voluntary intoxication.

¶5 In closing, the prosecution argued Elhoweris was guilty — not

as the shooter — but under a complicity theory. Trial counsel

countered that Elhoweris did not commit these crimes, he “was just

merely present” when they happened, and he was not guilty “by

association.” He also emphasized that Elhoweris was “in and out of

it,” directed the jury to the voluntary intoxication instruction, and

argued that because Elhoweris was incapacitated through “trauma”

2 and “perhaps through other substances,” he did not have the

requisite intent.

¶6 The jury convicted Elhoweris as charged. The trial court

imposed a controlling sentence of life in prison without the

possibility of parole. A division of this court affirmed the judgment.

People v. El-Howeris, (Colo. App. No. 16CA0653, Oct. 4, 2018) (not

published pursuant to C.A.R. 35(e)).

¶7 Elhoweris then moved for postconviction relief under Crim. P.

35(c), arguing, as relevant here, that trial counsel provided

ineffective assistance by failing to “adequately investigate and

present evidence of potential defenses of voluntary and involuntary

intoxication.”

¶8 The postconviction court denied that claim without a hearing,

concluding that Elhoweris “had not pled sufficient facts to establish

the failure to investigate or present an intoxication defense would

have likely changed the outcome at trial.”

II. Discussion

¶9 Elhoweris contends that the postconviction court erred when it

denied his claim without a hearing because he says the court

“applied the wrong legal standard.” We disagree.

3 A. Standard of Review and Legal Principles

¶ 10 To state a claim for ineffective assistance of counsel, a

defendant must allege facts sufficient to show that (1) counsel’s

performance was deficient, and (2) the deficient performance

prejudiced the defense. Dunlap v. People, 173 P.3d 1054, 1062

(Colo. 2007). Under the first prong of this test, the defendant must

identify acts or omissions of counsel that “fell below an objective

standard of reasonableness.” Strickland v. Washington, 466 U.S.

668, 687-88, 690 (1984). Under the second prong, the defendant

“must assert facts that, if true, show a reasonable probability that,

but for counsel’s unprofessional errors, the result of the proceeding

would have been different.” People v. Timoshchuk, 2018 COA 153,

¶ 22. “Reasonable probability means a probability sufficient to

undermine confidence in the outcome.” Id.

¶ 11 A postconviction court may deny a Crim. P. 35(c) motion

without a hearing if the motion, files, and record in the case clearly

establish that the allegations in the defendant’s motion do not

warrant postconviction relief. Ardolino v. People, 69 P.3d 73, 77

(Colo. 2003); see Crim. P. 35(c)(3)(IV). Thus, a court may deny the

motion without a hearing if, for example, the record refutes the

4 claims or if the allegations, even if true, fail to satisfy one or both

Strickland prongs. People v. Phipps, 2016 COA 190M, ¶ 19; see

People v. Duran, 2025 COA 34, ¶ 15.

¶ 12 We review de novo the denial of a Crim. P. 35(c) claim without

a hearing. People v. Cali, 2020 CO 20, ¶ 14.

B. Intoxication Defense

¶ 13 Even if we assume that Elhoweris’s postconviction motion

sufficiently alleged deficient performance with respect to

investigating and presenting an intoxication defense, we conclude

that the motion failed to sufficiently allege prejudice.

¶ 14 To be specific, the motion failed to allege facts to show a

reasonable probability that the outcome of the trial would have

been different had trial counsel investigated or presented an

intoxication defense. See Strickland, 466 U.S. at 694. What’s more,

the motion failed to allege sufficient facts to establish an

involuntary intoxication defense. That is, the motion didn’t allege

that the combination of ingesting Percocet, marijuana, and alcohol

“resulted in [Elhoweris’s] lack of capacity to conform his . . .

conduct to the requirements of law.” People v. Garcia, 113 P.3d

5 775, 783 (Colo. 2005); see also § 18-1-804, C.R.S. 2025 (explaining

and defining “[i]ntoxication”).

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
People v. Rodriguez
914 P.2d 230 (Supreme Court of Colorado, 1996)
White v. Denver District Court, Division 12
766 P.2d 632 (Supreme Court of Colorado, 1988)
Tucker v. DEPARTMENT OF RETIREMENT SYSTEMS
113 P.3d 4 (Court of Appeals of Washington, 2005)
Ardolino v. People
69 P.3d 73 (Supreme Court of Colorado, 2003)
v. Timoshchuk
2018 COA 153 (Colorado Court of Appeals, 2018)
People v. Cali
2020 CO 20 (Supreme Court of Colorado, 2020)
Dunlap v. People
173 P.3d 1054 (Supreme Court of Colorado, 2007)
People v. Duran
2025 COA 34 (Colorado Court of Appeals, 2025)

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