Peo v. Price

Colorado Court of Appeals·Decided July 23, 2026·No. 23CA0642·Unpublished

Opinion

23CA0642 Peo v Price 07-23-2026 COLORADO COURT OF APPEALS

Court of Appeals No. 23CA0642 City and County of Denver District Court No. 22CR2731 Honorable Eric M. Johnson, Judge

The People of the State of Colorado, Plaintiff-Appellee, v. Jamelle Price, Defendant-Appellant.

JUDGMENT AFFIRMED

Division III

Opinion by JUDGE MOULTRIE Bernard* and Taubman*, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e)

Announced July 23, 2026

Philip J. Weiser, Attorney General, Caitlin E. Grant, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Chloe Sovinee-Dyroff, 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. 2025.

¶1 Defendant, Jamelle Price, appeals the judgment of conviction entered after a jury found him guilty of two counts of possession of a weapon by a previous offender (POWPO) and driving after revocation prohibited (DARP). We affirm.

I. Background

¶2 While on patrol shortly after midnight, Officer Jacob Wolford and Officer Ryan Salg ran a license plate check on a car that Price was driving. The license plate came back as expired and didn’t match the car Price was driving, so the officers initiated a traffic stop.

¶3 Officer Wolford asked Price for the car’s registration, to which Price replied that he had “just bought” the car. Officer Wolford informed Price that the license plates were registered to a car other than the one Price was driving. Price offered to get the title to the car out of a backpack he had in the back seat, but Officer Wolford declined and asked Price for his ID.

¶4 Price gave Officer Wolford his state ID card. Officer Salg also obtained identification from a passenger in the front seat. The officers ran both names through their criminal history database and learned that Price’s driver’s license had been revoked and that he

was a habitual traffic offender (HTO). The passenger had two active warrants for his arrest. Shortly after the officers initiated the stop, a third officer — Officer Callee Heitz — arrived on scene to assist.

¶5 Officer Wolford and Officer Salg returned to the car and arrested Price.1 Before placing Price in a patrol car, Officer Wolford searched him and found six nine millimeter bullets in his pocket.

¶6 After confirming with Officer Wolford that Price was an HTO, Officer Heitz and Officer Salg began searching Price’s car and discovered a nine millimeter gun lodged between the front passenger seat and the center console. The officers searched a tan backpack and a black bag in the backseat and found the title to the car in the tan backpack. They also found a box with nine millimeter bullets in the backpack. Officer Heitz also searched the black bag and found a .22 caliber gun.

¶7 The prosecution charged Price with two counts of POWPO and later added one count of DARP.

¶8 Before trial, defense counsel filed a motion to suppress any evidence obtained from the officers’ search of Price’s car. At the

1 After the officers arrested Price, they also arrested the passenger on the outstanding warrants.

suppression hearing, defense counsel argued in relevant part that the officers’ inventory search was improper because the officers didn’t comply with the police department’s established procedures. The district court concluded that the officers had conducted a proper inventory search and denied Price’s motion.

¶9 A jury found Price guilty of all three charges. Price appeals his judgment of conviction, arguing that the court erred by denying his motion to suppress. He further argues that the POWPO jury instructions contained the wrong unit of prosecution, which resulted in a less than unanimous jury verdict. And he argues that the evidence wasn’t sufficient for his POWPO and DARP convictions. For the reasons discussed below, we disagree with each of his contentions.

II. Law Enforcement Officers’ Impoundment and Subsequent Inventory Search of Price’s Car Were Lawful

A. Additional Background

¶ 10 At the suppression hearing, defense counsel introduced into evidence the part of the operations manual for the Denver Police Department (DPD) that detailed its vehicle impoundment procedures. The manual gave officers discretion to “park and lock”

a vehicle if the driver was “arrested and impounding the vehicle is not required or permitted by policy, or it is determined to be necessary based upon the circumstances.” The manual listed HTO violations among the mandatory reasons for impounding a vehicle. According to the manual, officers’ inventory searches of impounded vehicles were required to follow established policies, including documenting in writing whether property was found in a vehicle, removing valuable items from the vehicle for storage at the police department, and securing any items of “minimal” value in the vehicle, if possible.

¶ 11 Defense counsel argued that the inventory search was unlawful because instead of documenting everything that was inside the car as required by DPD policy, officers only documented items of evidentiary value.

¶ 12 In support of its conclusion that the officers’ inventory search was lawful, the court found that (1) the officers were in a place they were legally allowed to be;

(2) the car wasn’t parked in a proper parking spot and “could not be left where it was”;

(3) there was no one available to drive the car away from the scene when the officers arrested Price;

(4) DPD’s policy specifically mandated impounding a vehicle when a driver had an HTO; and (5) the officers’ failure to follow their documentation policy “d[id] not undermine the propriety of the constitutionality” of their ability to search Price’s vehicle.

B. Applicable Legal Principles 1. Inventory Search and the Community Caretaking Exception

¶ 13 Under the Fourth Amendment, a search conducted without a warrant is presumptively unreasonable unless the search falls within an exception to the warrant requirement. People v. Brown, 2016 COA 150, ¶ 9 (Brown I), aff’d, 2018 CO 27 (Brown II). It’s the prosecution’s burden to establish an exception. Id.

¶ 14 One such exception is a vehicle inventory search conducted pursuant to law enforcement’s community caretaking responsibilities. Id. at ¶ 10. An inventory search doesn’t seek to obtain evidence but rather is “designed to protect the owner’s property while it is in police custody, to insure against claims concerning lost or damaged property, and to protect the police from

any danger posed by the contents of the vehicle.” Id. (citation omitted).

¶ 15 Officers can conduct a warrantless inventory search of a vehicle if the totality of the circumstances demonstrate that the officers, guided by standardized procedures, both impounded the vehicle and subsequently conducted an inventory search for valid community caretaking purposes. People v. Thomas, 2021 COA 23, ¶¶ 13-16. “[T]he decision to impound a vehicle and the ensuing inventory search are separate processes, both of which ‘must meet the strictures of the Fourth Amendment.’” Brown I, ¶ 11 (quoting United States v. Duguay, 93 F.3d 346, 351 (7th Cir. 1996)).

¶ 16 Whether a vehicle was properly impounded is thus the threshold inquiry to a court’s ultimate determination of whether an inventory search was reasonable. Id. After a vehicle is impounded, an inventory search conducted in accordance with an established, standardized procedure is generally considered reasonable in the absence of evidence that the officers conducted the search in bad faith or solely for investigative purposes. People v. Vaughn, 2014 CO 71, ¶ 14. But strict procedural compliance doesn’t necessarily render an inventory search reasonable under the Fourth

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