Peo v. Klingensmith

CourtColorado Court of Appeals
DecidedOctober 30, 2025
Docket23CA0571
StatusUnpublished

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

Opinion

23CA0571 Peo v Klingensmith 10-30-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 23CA0571 El Paso County District Court No. 20CR1269 Honorable Eric Bentley, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Eric J. Klingensmith,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division II Opinion by JUDGE MEIRINK Fox and Brown, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced October 30, 2025

Philip J. Weiser, Attorney General, Katherine Gillespie, Senior Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Katherine Brien, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Eric J. Klingensmith, was convicted of aggravated

sexual assault on a child, sexual assault on a child - position of

trust - pattern of abuse, aggravated incest, and attempt to commit

sexual assault on a child. Klingensmith appeals, contending that

the trial court violated his right to a speedy trial and should have

permitted him to cross-examine K.S.’s credibility on the basis that

she had previously falsely reported a sexual assault. We affirm.

I. Background

¶2 K.S. reported that her father, Klingensmith, began sexually

assaulting her when she was seven years old. The assaults

continued for several years. K.S. described that Klingensmith gave

her Ambien to forget the encounters.

¶3 K.S. reported that Klingensmith also sexually assaulted a

friend of hers, L.C. L.C. was interviewed and disclosed that when

she was nine or ten years old, she slept over at K.S.’s house.

During the sleepover, she was sent to the basement to sleep

because she and K.S. were being too loud. Klingensmith came

downstairs while L.C. was sleeping and removed her blanket. L.C.

stated that after the blanket was removed, she felt something

touching her upper thigh and she saw it was Klingensmith’s

1 genitals. L.C. stated that Klingensmith told her and K.S. that if

they said anything to the authorities, he would kill them.

¶4 Klingensmith was charged with sexual assault on a child by

one in a position of trust, two counts of sexual assault on a child,

sexual assault on a child - position of trust - victim less than fifteen

and as part of a pattern of abuse, and aggravated incest.

¶5 On the day Klingensmith’s trial was set to begin, the trial

court declared a mistrial under Crim. P. 24(c)(4) because the

COVID-19 pandemic prevented the court from safely empaneling a

jury. The trial was continued several more times.

¶6 The court severed the charges relating to K.S. from those

relating to L.C. The charges relating to K.S. were tried to a jury in

November 2022. The jury found Klingensmith guilty of sexual

assault on a child, sexual assault on a child - position of trust -

victim less than fifteen and as part of a pattern of abuse, and

aggravated incest.

¶7 The parties subsequently reached a plea agreement regarding

the counts relating to L.C. In November 2022, Klingensmith

pleaded guilty to an added count of attempted sexual assault on a

2 child in exchange for dismissal of the remaining counts involving

L.C.

¶8 The trial court sentenced Klingensmith to the custody of the

Department of Corrections for an indeterminate term of fourteen

years to life for sexual assault on a child and sexual assault on a

child - position of trust - pattern of abuse; an indeterminate term of

twelve years to life for aggravated incest; and a determinate term of

three years for attempted sexual assault on a child. The court

ordered the sentences to run concurrently.

II. Discussion

¶9 Klingensmith contends that the trial court erred (1) by

declaring a mistrial and refusing to dismiss the case on speedy trial

grounds because Crim. P. 24(c)(4) violates the separation of powers

doctrine and (2) by prohibiting defense counsel from cross-

examining K.S. concerning her prior allegations of sexual abuse

against her mother under section 18-3-407, C.R.S. 2022. We

disagree with both contentions.

3 A. Crim. P. 24(c)(4) Does Not Violate the Separation of Powers Doctrine

¶ 10 Klingensmith argues that the trial court lacked authority to

declare a mistrial under Crim. P. 24(c)(4) because that rule violates

the separation of powers doctrine. Crim. P. 24(c)(4) provides, “At

any time before trial, upon motion by a party or on its own motion,

the court may declare a mistrial in a case on the ground that a fair

jury pool cannot be safely assembled . . . due to a public health

crisis or limitations brought about by such crisis.” Klingensmith

argues that a defendant’s statutory right to a speedy trial is a

substantive right and that Crim. P. 24(c)(4) unconstitutionally

allows trial courts to extend the speedy trial timeline. We disagree.

1. Standard of Review and Applicable Law

¶ 11 “Whether a rule adopted by the supreme court is

constitutional is a question of law that we review de novo.” People

v. Eason, 2022 COA 54, ¶ 16; see People v. Pennington, 2021 COA

9, ¶ 25 (we review a separation of powers challenge de novo).

¶ 12 The Colorado Constitution vests the legislative, executive, and

judicial branches of government with distinct powers. Colo. Const.

art. III. The separation of powers doctrine limits each branch to the

4 exercise of only its powers. People v. Wiedemer, 852 P.2d 424, 436

(Colo. 1993). While the state’s legislative power is vested in the

General Assembly, the state’s judicial power is vested in the courts.

Colo. Const. art. V, § 1; Colo. Const. art. VI, § 1. This judicial

power includes the Colorado Supreme Court’s authority to

“promulgate rules governing practice and procedure in civil and

criminal cases.” Colo. Const. art. VI, § 21. However, “legislative

policy and judicial rulemaking powers may overlap to some extent

so long as there is no substantial conflict between statute and rule.”

People v. McKenna, 585 P.2d 275, 279 (Colo. 1978). “No such

conflict exists in the absence of a procedure conflicting with that set

forth in the statute.” People v. Bondurant, 2012 COA 50, ¶ 24. If a

substantial conflict exists, the statute prevails when it governs

traditional areas of legislative concern. § 13-2-108, C.R.S. 2025.

2. Analysis

¶ 13 Klingensmith argues that section 18-1-405, C.R.S. 2025,

which requires a defendant to be tried within six months from

entering a not-guilty plea, conflicts with and must prevail over

Crim. P. 24(c)(4) because the right to a speedy trial is substantive

and statutory. Klingensmith claims that Crim. P. 24(c)(4)

5 impermissibly broadens the meaning of a “mistrial,” but he fails to

point to any conflict between the statute and the rule that would

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