Peo v. Gallegos-Valdez

CourtColorado Court of Appeals
DecidedJuly 10, 2025
Docket21CA1942
StatusUnpublished

This text of Peo v. Gallegos-Valdez (Peo v. Gallegos-Valdez) 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. Gallegos-Valdez, (Colo. Ct. App. 2025).

Opinion

21CA1942 Peo v Gallegos-Valdez 07-10-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 21CA1942 Weld County District Court No. 19CR2084 Honorable Thomas J. Quammen, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Ivan Jose Gallegos-Valdez,

Defendant-Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division VI Opinion by JUDGE WELLING Kuhn and Schutz, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced July 10, 2025

Philip J. Weiser, Attorney General, Brock J. Swanson, First Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Andrea R. Gammell, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Ivan Jose Gallegos-Valdez appeals his convictions for

aggravated robbery, felony menacing, and aggravated motor vehicle

theft. Because we agree with Gallegos-Valdez’s contention that the

trial court erred by allowing the victim’s two identifications of him

to be admitted as evidence at trial, we reverse the convictions and

remand for a new trial.

I. Background

¶2 K.B. left his shift as a pizza delivery driver and walked to his

car. Just after he sat down and closed his car door, a man opened

the driver’s side door from the outside and told K.B. to leave the

keys in the ignition and move to the passenger seat. K.B. never saw

a weapon on the man but noticed him reach toward his hip, which

he took as a sign that the man was armed. K.B. got into the

passenger seat and promptly exited through the passenger door.

The man then sped away in K.B.’s car.

¶3 K.B. ran back to his employer and called 911 to report that his

car had been stolen. K.B. told the dispatcher that the man who

stole his car was “a Mexican guy” in his mid-twenties or early

thirties with “a little goatee” and wearing a white shirt and “regular

1 jeans.” Sergeant Matthew Rundle responded to the scene shortly

thereafter.

¶4 Sergeant Rundle obtained a limited description of the

perpetrator — mostly of his clothes — from K.B. at the scene and

began searching for surveillance cameras at nearby businesses.

Based on K.B.’s description, Sergeant Rundle obtained footage of a

man inside a nearby liquor store around the time of the vehicle

theft. Sergeant Rundle presented K.B. with a screenshot of the

liquor store surveillance footage. He told K.B., “[W]e saw the crime

happen, and the individual, before the crime happened, went into

the liquor store.” Then Sergeant Rundle asked K.B., “Is this the guy

that stole your vehicle?” K.B. got excited and said, “That’s him.

That’s him. That’s him.”

¶5 The next day, after determining that the man from the

screenshot was Gallegos-Valdez, Sergeant Rundle asked K.B. to

come to the police station to participate in a photo array

identification. When Sergeant Rundle showed K.B. the array of six

photos, K.B. immediately identified the photograph of Gallegos-

Valdez as the person who had stolen his car.

2 ¶6 Gallegos-Valdez was arrested and charged with three felonies

— robbery, theft, and menacing. Prior to trial, Gallegos-Valdez

moved to suppress the initial show-up identification as unduly

suggestive and all the subsequent identifications as tainted by the

initial one. The trial court held a hearing that spanned three days

during which Seargent Rundle testified about his investigation that

led to K.B.’s two identifications of Gallegos-Valdez. K.B. didn’t

testify at the suppression hearing. While the court found that the

show-up identification was suggestive, it concluded that K.B.’s

identification was sufficiently reliable to admit as evidence.

¶7 At trial, K.B. testified that the man who stole his car wore a

white t-shirt, a grey backward flat-billed hat, and “jean-like

clothing,” and had a goatee. K.B. also testified that the perpetrator

was Mexican and didn’t have any face tattoos. The jury found

Gallegos-Valdez guilty of aggravated robbery, felony menacing, and

aggravated motor vehicle theft.

II. Discussion

A. Issues on Appeal

¶8 Gallegos-Valdez advances four contentions on appeal.

Specifically, he contends that the trial court erred when it (1) denied

3 his motion to suppress K.B.’s identification of him; (2) allowed an

officer to testify about video evidence not admitted at trial;

(3) allowed expert testimony under the guise of lay testimony; and

(4) expanded the deadly weapon element of robbery and menacing.

Gallegos-Valdez also argues that the cumulative effect of these

errors deprived him of his right to a fair trial. Because we agree

that the court erred by admitting K.B.’s identification of Gallegos-

Valdez, and because this error requires reversal, we don’t address

his other arguments, which are unlikely to arise in the same

posture on remand.

B. The Identification

¶9 Gallegos-Valdez contends that the trial court improperly

declined to suppress evidence of the show-up identification because

the procedures used were impermissibly suggestive and the

following identifications were unreliable under the totality of the

circumstances. We agree with the trial court’s conclusion that the

show-up identification procedure was suggestive. But the evidence

doesn’t support the trial court’s conclusion that K.B.’s

identifications were nonetheless reliable and therefore admissible.

4 1. Applicable Law and Standard of Review

¶ 10 A court analyzes a claim that an identification procedure was

unduly suggestive in two parts. First, the court must determine if

the identification procedure was impermissibly suggestive. People

v. Williams, 2019 COA 32, ¶ 8. Then, the court has to determine if

the subsequent identification is reliable. Id. at ¶ 10.

¶ 11 Initially, the defendant has the burden of proving that an

identification procedure used by the State was “impermissibly

suggestive.” Bernal v. People, 44 P.3d 184, 191 (Colo. 2002). An

impermissibly suggestive procedure may “give rise to a very

substantial likelihood of irreparable misidentification.” People v.

Jaquez, 2018 COA 76, ¶ 49. A one-on-one identification — also

referred to as a “show-up” identification — occurs when the

eyewitness is asked to identify a single person who appears in-

person or through a video or photograph. Such procedures are

disfavored and “tend to be suggestive” because they are more likely

to lead to a mistaken identification than a lineup. People v. Walker,

666 P.2d 113, 119 (Colo. 1983); People v. McCants, 2021 COA 138,

¶ 19.

5 ¶ 12 An eyewitness may also be asked to identify a suspect through

the presentation of an array of photos depicting people with similar

characteristics. There are several factors that a court should

consider when determining if a photo array identification procedure

is unduly suggestive, including (1) the size of the array; (2) the

manner of its presentation; and (3) the details of the photographs.

Williams, ¶ 9. A procedure that only includes one photo that

matches the description of the perpetrator can be impermissibly

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Related

Neil v. Biggers
409 U.S. 188 (Supreme Court, 1972)
Burks v. United States
437 U.S. 1 (Supreme Court, 1978)
People v. Walker
666 P.2d 113 (Supreme Court of Colorado, 1983)
People v. Watkins
553 P.2d 819 (Supreme Court of Colorado, 1976)
Bernal v. People
44 P.3d 184 (Supreme Court of Colorado, 2002)
People v. Borghesi
66 P.3d 93 (Supreme Court of Colorado, 2003)
People v. Jaquez
2018 COA 76 (Colorado Court of Appeals, 2018)
Zoll v. People
2018 CO 70 (Supreme Court of Colorado, 2018)
v. Williams
2019 COA 32 (Colorado Court of Appeals, 2019)
v. Daley
2021 COA 85 (Colorado Court of Appeals, 2021)
People v. Null
233 P.3d 670 (Supreme Court of Colorado, 2010)
Hagos v. People
2012 CO 63 (Supreme Court of Colorado, 2012)
People v. Mascarenas
666 P.2d 101 (Supreme Court of Colorado, 1983)

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