Peo v. Germanson

CourtColorado Court of Appeals
DecidedMay 1, 2025
Docket22CA0368
StatusUnpublished

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

Opinion

22CA0368 Peo v Germanson 05-01-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 22CA0368 City and County of Denver District Court No. 19CR8178 Honorable David H. Goldberg, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Jacob L. Germanson,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division VII Opinion by JUDGE HAWTHORNE* Lipinsky and Johnson, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 1, 2025

Philip J. Weiser, Attorney General, Claire V. Collins, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Meghan M. Morris, Deputy State Public Defender, 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. 2024. ¶1 Defendant, Jacob L. Germanson, appeals the judgment of

conviction entered on jury verdicts finding him guilty of two counts

of sexual assault, one count of second degree assault

(strangulation), and one count of third degree assault. We affirm.

I. Background

¶2 In late October 2019, the victim, R.T., called the police to

report that her boyfriend — Germanson — had sexually assaulted

her. Less than thirty minutes later, Germanson called the police to

report that his girlfriend — R.T. — would call them to falsely report

he had sexually assaulted her. The police arrested Germanson, and

the prosecution filed a complaint and information charging1 him

with two counts of sexual assault with force under section

18-3-402(1)(a), (4), C.R.S. 2019; one count of second degree assault

for strangulation under section 18-3-203(1)(i), C.R.S. 2024; and one

count of third degree assault under section 18-3-204(1)(a), C.R.S.

2019.

¶3 Germanson asserted that R.T. consented to engage in sexual

intercourse with him, but that she later filed a false police report

1 For statutes that have since changed, we apply the versions in

effect at the time of the underlying incident.

1 against him because she became angry upon learning that he was

not divorced from his wife.

¶4 The case proceeded to a jury trial. As noted above, the jury

found Germanson guilty of two counts of sexual assault, one count

of second degree assault (strangulation), and one count of third

degree assault. On one of the sexual assault counts, the jury found

that Germanson caused R.T.’s submission through force or

violence, which enhanced that count from a class 4 felony to a class

3 felony under section 18-3-402(4)(a), C.R.S. 2019.

¶5 On appeal, Germanson contends that the district court abused

its discretion by (1) improperly admitting as res gestae evidence his

communications with R.T. in the days leading up to the sexual

encounter; (2) allowing a domestic violence expert (the DV expert) to

testify beyond the scope of the prosecution’s disclosure of her

anticipated testimony; and (3) permitting a sexual assault nurse

examiner (SANE) to testify beyond her expertise and allowing her to

comment on R.T.’s credibility. Germanson also contends that we

should reverse his judgment of conviction under the cumulative

error doctrine.

2 II. Standard of Review

¶6 We review a trial court’s evidentiary rulings — such as rulings

on admission of exhibits and expert testimony — for an abuse of

discretion. People v. Rector, 248 P.3d 1196, 1200 (Colo. 2011). A

court abuses its discretion when its decision is manifestly arbitrary,

unreasonable, or unfair, or is based on misapprehending or

misapplying the law. People v. Kendrick, 2017 CO 82, ¶ 36.

Determining whether a court misapprehended or misapplied the law

“does not require deference to the trial court. Instead, the trial

court’s application or interpretation of the law when making an

evidentiary ruling is a question of law we review de novo.” People v.

Dominguez, 2019 COA 78, ¶ 13.

¶7 “[W]e review nonconstitutional trial errors that were preserved

by objection for harmless error,” meaning “we reverse if the error

‘substantially influenced the verdict or affected the fairness of the

trial proceedings.’” Hagos v. People, 2012 CO 63, ¶ 12 (quoting

Tevlin v. People, 715 P.2d 338, 342 (Colo. 1986)).

¶8 We review unpreserved errors for plain error and reverse such

errors only if they “so undermined the fundamental fairness of the

trial itself so as to cast serious doubt on the reliability of the

3 judgment of conviction.” Hagos, ¶ 14 (quoting People v. Miller, 113

P.3d 743, 750 (Colo. 2005)).

III. Admitting Evidence under the Res Gestae Doctrine

A. Additional Background

¶9 The district court held a pretrial hearing on the prosecution’s

“Notice of Intent to Introduce Res Gestae and 404(B) Evidence” and

Germanson’s response to the notice. The prosecution sought to

introduce text messages and telephone calls between R.T. and

Germanson in the two days leading up to the assault as res gestae

and CRE 404(b) evidence.

¶ 10 The court found that the communications evinced

Germanson’s “motive, opportunity, intent, and preparation” for the

charged assaults and that the communications were “res gestae of

the events and the incidents in this case as alleged in the

information and complaint.” It also found that, under People v.

Spoto, 795 P.2d 1314, 1318 (Colo. 1990), the communications

related to a material fact, were logically relevant and had a tendency

to make the material fact’s existence more or less probable than

without the communications, and were not being submitted to

establish Germanson’s bad character. Considering all the evidence,

4 the court found that the communications’ probative value

outweighed the danger of unfair prejudice and concluded they were

also admissible under CRE 404(b).

¶ 11 Later, Germanson filed a motion in limine in which he asked

the court to provide a contemporaneous limiting instruction before

receiving any evidence under CRE 404(b). The court denied

Germanson’s request without prejudice, reasoning that the request

was premature, and said it would “consider a limiting instruction if

and when testimony [was] introduced and if and when [it]

determine[d] that an . . . instruction [was] appropriate.” During the

jury instruction conference, after the court admitted the

communications into evidence, Germanson proposed an instruction

to limit the communications’ purpose under CRE 404(b). The court

rejected the proposed limiting jury instruction and found that the

communications were “res gestae and not [CRE] 404(b)” evidence.

B. Applicable Legal Principles

¶ 12 “Evidence of any other crime, wrong, or act is not admissible

to prove a person’s character in order to show that on a particular

occasion the person acted in conformity with the character.” CRE

404(b)(1). However, under CRE 404(b)(2), “[t]his evidence may be

5 admissible for another purpose, such as proving motive,

opportunity, intent, preparation, plan, knowledge, identity, absence

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Related

United States v. Robert McPartlin
595 F.2d 1321 (Seventh Circuit, 1979)
People v. Anderson
837 P.2d 293 (Colorado Court of Appeals, 1992)
Brooks v. People
975 P.2d 1105 (Supreme Court of Colorado, 1999)
People v. Graham
678 P.2d 1043 (Colorado Court of Appeals, 1983)
People v. Quintana
882 P.2d 1366 (Supreme Court of Colorado, 1994)
Tevlin v. People
715 P.2d 338 (Supreme Court of Colorado, 1986)
People v. Greer
262 P.3d 920 (Colorado Court of Appeals, 2011)
People v. Ramirez
155 P.3d 371 (Supreme Court of Colorado, 2007)
People v. Lafferty
9 P.3d 1132 (Colorado Court of Appeals, 1999)
People v. Shreck
22 P.3d 68 (Supreme Court of Colorado, 2001)
People v. Jenkins
83 P.3d 1122 (Colorado Court of Appeals, 2003)
People v. Kendrick
2017 CO 82 (Supreme Court of Colorado, 2017)
v. Cooper
2019 COA 21 (Colorado Court of Appeals, 2019)
v. Dominguez
2019 COA 78 (Colorado Court of Appeals, 2019)
Phillips v. People
2019 CO 72 (Supreme Court of Colorado, 2019)
Howard-Walker v. People
2019 CO 69 (Supreme Court of Colorado, 2019)
v. Dyer
2019 COA 161 (Colorado Court of Appeals, 2019)
People v. Miller
113 P.3d 743 (Supreme Court of Colorado, 2005)
People v. Brown
313 P.3d 608 (Colorado Court of Appeals, 2011)
People v. Spoto
795 P.2d 1314 (Supreme Court of Colorado, 1990)

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