Peo v. Garcia

Colorado Court of Appeals·Decided November 6, 2025·No. 24CA0899·Unpublished

Opinion

24CA0899 Peo v Garcia 11-06-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0899 City and County of Denver District Court No. 19CR5690 Honorable Karen L. Brody, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Kenneth Louis Garcia,

Defendant-Appellant.

ORDER AFFIRMED

Division IV Opinion by JUDGE HARRIS Schock and Berger*, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced November 6, 2025

Philip J. Weiser, Attorney General, Brian M. Lanni, Senior Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Kenneth Louis Garcia, Pro Se

*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 Defendant, Kenneth Louis Garcia, appeals the denial of his

Crim. P. 35(c) motion without a hearing. We affirm.

I. Background

¶2 After Garcia stole property from an elderly homeowner who

had hired him to perform yard work, he was charged with multiple

counts of theft and giving false information to a pawnbroker.

¶3 Trial was set for July 2020, during the height of the COVID-19

pandemic, when most jury trials had been suspended by order of

the Chief Justice of the Colorado Supreme Court. The Chief Justice

granted an exemption, however, to allow two test trials to proceed,

one of which was Garcia’s. The jury found Garcia guilty of all

charges, and the court sentenced him to a controlling term of nine

years in prison.

¶4 On direct appeal, Garcia argued:

• Several of the trial court’s COVID-19 protocols — specifically,

requiring prospective and impaneled jurors to wear masks,

assigning prospective jurors to the jury selection room in the

order they checked in, and seating the impaneled jurors

throughout the courtroom rather than in the jury box —

violated his constitutional rights.

1 • The court erred by conducting voir dire in his absence.

• The court erred by admitting expert valuation testimony.

• The prosecution committed misconduct.

• The evidence was insufficient to support his convictions.

A division of this court rejected those arguments and affirmed the

judgment of conviction. See People v. Garcia, 2022 COA 144, ¶ 1.

¶5 While the direct appeal was pending, Garcia filed a pro se

Crim. P. 35(c) motion for postconviction relief, and, once the

mandate issued, he filed several addendums to the motion

(together, the Rule 35(c) motion). The Rule 35(c) motion alleged

numerous trial court errors and ineffective assistance of counsel

claims.

¶6 In a thorough, written order, the postconviction court denied

the Rule 35(c) motion without conducting an evidentiary hearing.

The court concluded that Garcia was not entitled to postconviction

relief because his claims were successive, vague and conclusory, or

directly refuted by the record.

2 II. Analysis

¶7 On appeal, Garcia reasserts many, but not all, of the claims

raised in his Rule 35(c) motion.1 He contends that the

postconviction court erred by summarily denying these claims. We

disagree.

A. Standard of Review

¶8 We review de novo a postconviction court’s order denying a

Crim. P. 35(c) motion without a hearing. People v. Nozolino, 2023

COA 39, ¶ 7.

B. Successive Claims

¶9 Crim. P. 35(c) allows a defendant to challenge a judgment of

conviction on the grounds that it was obtained in violation of his

constitutional or statutory rights. See Crim. P. 35(c)(2)(I)-(II); People

v. Valdez, 178 P.3d 1269, 1279 (Colo. App. 2007). But a defendant

is not entitled to perpetual review of his postconviction claims.

People v. Melendez, 2024 COA 21M, ¶ 38. Therefore, absent limited

exceptions not relevant here, a postconviction court must deny any

1 Claims that were raised in the Rule 35(c) motion but not

reasserted on appeal are deemed abandoned. See People v. Ortega, 266 P.3d 424, 428 (Colo. App. 2011).

3 successive claim. See Crim. P. 35(c)(3)(VI)-(VII); see also People v.

Taylor, 2018 COA 175, ¶ 17 (the language directing a court to deny

successive postconviction claims is “mandatory rather than

permissive”). A claim is successive if it was already resolved on

appeal or in a prior postconviction proceeding, Crim. P. 35(c)(3)(VI),

or it could have been raised in an earlier appeal or postconviction

proceeding, Crim. P. 35(c)(3)(VII). In other words, claims cannot be

raised more than once, and they must be raised at the first

opportunity.

¶ 10 We conclude that most of the claims Garcia raised in his Rule

35(c) motion and reasserted on appeal are successive because they

4 were resolved on direct appeal or could have been raised on direct

appeal.2

• Claim No. 2. The claim that the trial court erred by proceeding

with the trial even after a juror was exposed to COVID-19 and

was replaced with an alternate juror could have been raised on

direct appeal.

• Claim No. 3. The claim that the victim committed perjury in

her victim impact statement could have been raised on direct

appeal.

• Claim No. 4. The claim that the mittimus contained an error

could have been raised on direct appeal. Regardless, the trial

2 To the extent Garcia includes allegations of ineffective assistance

of counsel within certain of his claims — i.e., that counsel sat too far away from him at trial, that counsel should have challenged an alleged false statement in the victim impact statement, that he did not have enough time to consult with his lawyer before sentencing, and that counsel did not properly represent him at trial or at sentencing — those claims are vague and conclusory because they lack specific factual allegations concerning deficient performance or prejudice. See People v. Delgado, 2019 COA 55, ¶ 8; see also Strickland v. Washington, 466 U.S. 668, 687 (1984) (To prevail on an ineffective assistance of counsel claim, “the defendant must show that counsel’s performance was deficient” and “that the deficient performance prejudiced his defense.”).

5 court issued an amended mittimus correcting the error in

January 2024.3

• Claim No. 5. The claim that the trial court erred by allowing

the victim to be referred to as “Dr. Kerr” could have been

raised on direct appeal. In addition, according to the

postconviction court, the victim testified at trial that she

earned a Ph.D. from Columbia University. See People v.

Duran, 2025 COA 34, ¶ 15 (The court may deny a

postconviction claim without a hearing when “the record

directly refutes the allegations.”).

• Claim No. 6. The claim that the trial court erred by admitting

expert valuation testimony was raised and resolved on direct

appeal. See Garcia, ¶ 54.

• Claim No. 7. The claim that the trial court closed the

courtroom to the public, including members of Garcia’s family,

could have been raised on direct appeal.

3 To the extent Garcia argues that the error in the mittimus affected

Free access — add to your briefcase to read the full text and ask questions with AI

Peo v. Garcia, (Colo. Ct. App. 2025).

Peo v. Garcia (Peo v. Garcia) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
DePineda v. Price
915 P.2d 1278 (Supreme Court of Colorado, 1996)
People v. Valdez
178 P.3d 1269 (Colorado Court of Appeals, 2007)
v. Taylor
2018 COA 175 (Colorado Court of Appeals, 2018)
People v. Delgado
2019 COA 55 (Colorado Court of Appeals, 2019)
People v. Ortega
266 P.3d 424 (Colorado Court of Appeals, 2011)
People v. Duran
2025 COA 34 (Colorado Court of Appeals, 2025)