Peo v. Snider

CourtColorado Court of Appeals
DecidedAugust 7, 2025
Docket23CA2108
StatusUnpublished

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

Opinion

23CA2108 Peo v Snider 08-07-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 23CA2108 Rio Blanco County District Court No. 09CR56 Honorable Denise K. Lynch, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Jerry D. Snider,

Defendant-Appellant.

ORDER AFFIRMED

Division V Opinion by JUDGE GROVE Welling and Johnson, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced August 7, 2025

Philip J. Weiser, Attorney General, Carmen Moraleda, Senior Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Erin Wigglesworth, Alternate Defense Counsel, Denver, Colorado, for Defendant-Appellant ¶1 Jerry D. Snider appeals the postconviction court’s order

denying his petition for postconviction relief without a hearing. We

affirm.

I. Background

¶2 A jury found Snider guilty of one count each of first degree

murder and aggravated robbery. The convictions were based on

evidence that, sometime between the evening of July 2 and the

morning of July 3, 2009, Snider struck his sleeping father in the

head with a hatchet, dragged him to the floor, struck him several

more times, and took his wallet. People v. Snider, slip op. at 1

(Colo. App. No. 11CA2579, Apr. 21, 2016) (not published pursuant

to C.A.R. 35(e)) (Snider I). Snider fled the scene in Rio Blanco

County but turned himself in at the Clear Creek County Sherriff’s

Office later in the day. Id. Thereafter, he was transferred to Denver

Health Medical Center for mental health care, and later, to the

Colorado Mental Health Institute at Pueblo (CMHIP) for evaluation

of his competency, sanity, and mental condition.

¶3 Snider entered a plea of not guilty by reason of insanity

(NGRI). At trial, his attorneys advanced the theory that, at the time

he killed his father, Snider “was experiencing the psychotic

1 symptoms of paranoid schizophrenia to the degree that he could not

distinguish moral right from wrong.” Rather, his “paranoid

schizophrenic delusions and hallucinations made him believe that

his father was part of a plot to kill” him such that it seemed he was

in imminent danger of being killed by another and had to use

deadly force to defend himself.

¶4 After the jury’s verdict, the trial court adjudicated Snider an

habitual criminal. For the first degree murder count, the court

sentenced him to life in prison without the possibility of parole.

And for the aggravated robbery count, the court imposed a

consecutive forty-eight-year prison sentence. Snider appealed his

convictions and sentence, and a division of this court affirmed. Id.

The appellate mandate was issued on June 7, 2017.

¶5 Five years later, Snider filed a pro se postconviction motion

asserting claims under both Crim. P. 35(a) and (c). Appointed

counsel then filed a supplement asserting that (1) Snider’s

aggravated robbery sentence was not authorized by law and raised

an inference of gross disproportionality; and (2) Snider’s trial

attorneys provided ineffective assistance. In particular, the

supplement alleged that counsel performed deficiently by:

2 1. conceding that Snider’s mental condition did not prevent

him from forming the requisite culpable mental states

because counsel called Dr. Karen Fukutaki, who, in

Snider’s view, was the only expert who testified that he

could form such a mental state;

2. failing to properly endorse Dr. Lennart Abel as an expert,

thus precluding the defense from asking Dr. Abel

whether Snider was able to form the culpable mental

state for first degree murder;

3. failing to ask any expert for their opinion regarding

Snider’s ability to form the culpable mental state for

aggravated robbery and generally “disregard[ing]” the

aggravated robbery charge;

4. failing to investigate and present evidence in support of

an involuntary toxication defense based on medications

Snider was prescribed and took as directed just before

the crimes occurred;

5. failing to call Dr. Ethan Swift, the Denver Health doctor

who evaluated Snider’s mental health in the days

immediately following his arrest; and

3 6. failing to effectively argue the issue of “settled insanity” in

support of an instruction on how the presence of prior

drug use may not in all circumstances deprive a

defendant of an insanity defense.

¶6 After receiving the prosecution’s response, the postconviction

court denied the motion in a written order. The court rejected

Snider’s Crim. P. 35(a) claim, concluding that the aggravated

robbery sentence was lawful. As to Snider’s Crim. P. 35(c) claims

related to aggravated robbery, the court found that (1) the claims

were untimely, and he had failed to demonstrate justifiable excuse

or excusable neglect for his late filing; and (2) the proportionality

claim was raised and resolved in his direct appeal.1

¶7 The court then rejected Snider’s claims of ineffective

assistance of counsel related to his first degree murder conviction.

The court concluded that counsel did not perform deficiently by

failing to make a more effective argument for an instruction on

“settled insanity” because settled insanity has been rejected as a

1 In his reply brief, Snider concedes that his request for a second

review of the proportionality of his aggravated robbery sentence has been foreclosed by the Colorado Supreme Court’s recent opinion in McDonald v. People, 2024 CO 75.

4 defense in Colorado. As to the remaining ineffective assistance

claims, the court determined that all of the alleged deficiencies were

strategic decisions on the part of counsel. In the alternative, the

court concluded that Snider was not prejudiced by any of counsel’s

alleged deficiencies because the evidence of his guilt was

overwhelming.

II. Crim. P. 35(a)

¶8 We first reject Snider’s claim that his aggravated robbery

sentence is illegal.

¶9 A sentence is illegal if it is inconsistent with the statutory

sentencing scheme outlined by the legislature. People v. Wenzinger,

155 P.3d 415, 418 (Colo. App. 2006). Such a sentence may be

corrected at any time. Crim. P. 35(a). The legality of a sentence is a

question of law that we review de novo. People v. Bassford, 2014

COA 15, ¶ 20.

¶ 10 Snider asserts that his forty-eight-year aggravated robbery

sentence does not comply with statutory requirements because the

sentencing court erroneously found that “the habitual sentencing

requirements preempted the requirement to sentence [him] as

mandated by [section] 18-4-302(4),” C.R.S. 2024.

5 ¶ 11 Section 18-4-302(4) states that a defendant convicted of

aggravated robbery pursuant to section 18-4-302(1)(b), “shall” be

sentenced “in accordance with the provisions of section 18-1.3-

406,” C.R.S. 2024 (the crime of violence statute). The crime of

violence statute requires any person convicted of a crime of violence

to be sentenced to a term of incarceration of at least the midpoint

in, but not more than twice the maximum of, the presumptive

range, as modified for an extraordinary risk crime. § 18-1.3-

406(1)(a). Thus, a conviction under subsection (1)(b) of the

aggravated robbery statute normally requires a sentence of ten to

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

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Robles v. People
811 P.2d 804 (Supreme Court of Colorado, 1991)
People v. Rodriguez
914 P.2d 230 (Supreme Court of Colorado, 1996)
People v. Hoefer
961 P.2d 563 (Colorado Court of Appeals, 1998)
People v. Pena
794 P.2d 1070 (Colorado Court of Appeals, 1990)
Bieber v. People
856 P.2d 811 (Supreme Court of Colorado, 1993)
People v. Wiedemer
852 P.2d 424 (Supreme Court of Colorado, 1993)
Ardolino v. People
69 P.3d 73 (Supreme Court of Colorado, 2003)
People v. Wenzinger
155 P.3d 415 (Colorado Court of Appeals, 2006)
People v. Duran
2015 COA 141 (Colorado Court of Appeals, 2015)
People v. Chipman
2015 COA 142 (Colorado Court of Appeals, 2015)
People v. Chavez-Torres
2019 CO 59 (Supreme Court of Colorado, 2019)
People v. Cali
2020 CO 20 (Supreme Court of Colorado, 2020)
Peo v. Houser
2020 COA 128 (Colorado Court of Appeals, 2020)
Dunlap v. People
173 P.3d 1054 (Supreme Court of Colorado, 2007)
People v. Voth
2013 CO 61 (Supreme Court of Colorado, 2013)
People v. Newmiller
2014 COA 84 (Colorado Court of Appeals, 2014)
People v. Bassford
2014 COA 15 (Colorado Court of Appeals, 2014)
Rodney Dewayne McDonald v. The People of the State of Colorado.
2024 CO 75 (Supreme Court of Colorado, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Peo v. Snider, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-v-snider-coloctapp-2025.