Peo v. Villegas-Ortega

CourtColorado Court of Appeals
DecidedJune 5, 2025
Docket22CA1509
StatusUnpublished

This text of Peo v. Villegas-Ortega (Peo v. Villegas-Ortega) 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. Villegas-Ortega, (Colo. Ct. App. 2025).

Opinion

22CA1509 Peo v Villegas-Ortega 06-05-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 22CA1509 City and County of Denver District Court No. 20CR3893 Honorable Brian R. Whitney, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Oscar D. Villegas-Ortega,

Defendant-Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

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

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced June 5, 2025

Philip J. Weiser, Attorney General, Austin R. Johnston, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Law Office of Mark Burton, P.C., K. Mark Burton, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Oscar D. Villegas-Ortega, appeals his judgment of

conviction upon a jury verdict finding him guilty of murder in the

first degree (extreme indifference), first degree assault (deadly

weapon), and reckless manslaughter. We reverse and remand the

case for a new trial.

I. Background

¶2 Based on the evidence presented at trial, a jury could find the

following facts.

¶3 Villegas-Ortega attended a birthday party for the one-year-old

daughter of his cousin, Karina Lujan, at a restaurant near

downtown Denver. The party was also attended by Edward

Armenta, Lujan’s ex-boyfriend and the one-year-old’s father.

¶4 Around fifty friends and family attended the party, which had

a band, a DJ, and an open bar, and lasted from three p.m. until

midnight.

¶5 At one point, Villegas-Ortega danced with Lujan, his cousin,

and Armenta noticed. After the dance, Armenta and his friends

confronted Villegas-Ortega and told him he should not be dancing

with Lujan. After a few additional interactions, Villegas-Ortega’s

father signaled to his son that they should leave the party because

1 Armenta and his friends were “trying to start stuff.” (For his part,

Armenta denied the dance upset him or his friends or caused any

confrontation. He claimed that it was instead Villegas-Ortega who

“wasn’t happy.”)

¶6 A number of men — Villegas-Ortega, his father, Armenta,

Armenta’s brother, his friend Fausto Martinez, and others — ended

up outside the front of the restaurant, where a melee broke out.

Villegas-Ortega, who testified at trial, said he and his father were

surrounded when he saw someone “about to pull out a gun, so I

pulled my gun out.” More fighting ensued, shots were fired, and

someone brandished a knife. Martinez was fatally shot and

Armenta and his brother suffered knife wounds.

¶7 As relevant to this appeal, the prosecution charged Villegas-

Ortega with the first degree murder of Martinez under two

theories — (1) after deliberation and (2) extreme indifference. Later,

it amended the complaint to add counts of second degree assault,

naming Armenta as the victim, and first degree assault, naming

Armenta’s brother as the victim. After a trial, at which Villegas-

Ortega maintained that he acted in self-defense, the jury found

Villegas-Ortega guilty of extreme indifference murder, reckless

2 manslaughter (which was submitted to the jury as a lesser included

offense to the charge of first degree murder after deliberation), and

first degree assault. The jury acquitted Villegas-Ortega of first

degree murder after deliberation, the lesser included offense of

second degree murder, and second degree assault. The trial court

sentenced Villegas-Ortega to a controlling sentence of life in prison

without parole. This appeal followed.

II. Jury Instructions

¶8 Because numerous people were involved in the fight, Villegas-

Ortega contends that the court reversibly erred when it rejected a

defense-tendered jury instruction that would have explicitly

directed the jury to consider the totality of the circumstances when

evaluating his claim of self-defense. He also argues that the trial

court plainly erred when, part way through deliberations, it

instructed the jury that it should consider the totality of the

circumstances with respect to first degree murder after deliberation

and the lesser included second degree murder charge while failing

to apply that supplemental instruction to the charges of extreme

3 indifference murder, reckless manslaughter, and first degree

assault. We agree that reversal is required.1

A. Standard of Review and Applicable Law

¶9 We review jury instructions de novo to determine whether the

instructions accurately informed the jury of the governing law.

Riley v. People, 266 P.3d 1089, 1092 (Colo. 2011). When defense

counsel fails to object, we review the issue for plain error. Hagos v.

People, 2012 CO 63, ¶ 14. We reverse if the error “so undermined

the fundamental fairness of the trial itself so as to cast serious

doubt on the reliability of the judgment of conviction.” People v.

Miller, 113 P.3d 743, 750 (Colo. 2005) (quoting People v. Sepulveda,

65 P.3d 1002, 1006 (Colo. 2003)). As applied to jury instructions,

the defendant must demonstrate not only that the instruction

affected a substantial right, but also that the record reveals a

reasonable possibility that the error contributed to his conviction.

Id.

1 Because it is unlikely to arise in the same manner on retrial, we

do not reach Villegas-Ortega’s unrelated contention that the court allowed the prosecution to improperly impeach him as to whether he was allowed to possess a firearm. If it does arise, the trial court retains discretion to rule under those circumstances. See People v. Davis, 312 P.3d 193, 196-97 (Colo. App. 2010), aff’d, 2013 CO 57.

4 ¶ 10 The trial court has a duty to instruct the jury on all matters of

law applicable to the case. People v. Garcia, 28 P.3d 340, 343 (Colo.

2001) (citing Hansen v. State Farm Mut. Auto. Ins. Co., 957 P.2d

1380, 1384 (Colo. 1998)). A defendant is entitled to an instruction

on his theory of defense. People v. Tippett, 733 P.2d 1183, 1195

(Colo. 1987). It is not error, however, for a trial court to refuse to

give a defense theory instruction when the contents of that

instruction are embodied in other instructions given by the trial

court. Id. We consider all the instructions given by the trial court

together to determine whether they properly informed the jury.

People v. Trujillo, 83 P.3d 642, 645 (Colo. 2004); Tippett, 733 P.2d at

1195.

B. Additional Facts

¶ 11 The defense’s theory of the case was that Villegas-Ortega acted

in self-defense. Before trial, counsel tendered two jury instructions

regarding self-defense in a multiple assailants situation.

¶ 12 The first proposed instruction (the apparent necessity

instruction) stated:

It is fundamental that the law of self-defense, which is emphatically a law of necessity, involves the question of one’s right to act upon

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Related

People v. Tippett
733 P.2d 1183 (Supreme Court of Colorado, 1987)
Hansen v. State Farm Mutual Automobile Insurance Co.
957 P.2d 1380 (Supreme Court of Colorado, 1998)
People v. Jones
675 P.2d 9 (Supreme Court of Colorado, 1984)
Cassels v. People
92 P.3d 951 (Supreme Court of Colorado, 2004)
Beckett v. People
800 P.2d 74 (Supreme Court of Colorado, 1990)
People v. Bachofer
192 P.3d 454 (Colorado Court of Appeals, 2008)
People v. Trujillo
83 P.3d 642 (Supreme Court of Colorado, 2004)
Johnson v. People
2019 CO 17 (Supreme Court of Colorado, 2019)
v. Roberts-Bicking
2021 COA 12 (Colorado Court of Appeals, 2021)
People v. Garcia
28 P.3d 340 (Supreme Court of Colorado, 2001)
People v. Sepulveda
65 P.3d 1002 (Supreme Court of Colorado, 2003)
Riley v. People
266 P.3d 1089 (Supreme Court of Colorado, 2011)
People v. Pickering
276 P.3d 553 (Supreme Court of Colorado, 2011)
People v. Davis
312 P.3d 193 (Colorado Court of Appeals, 2010)

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Peo v. Villegas-Ortega, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-v-villegas-ortega-coloctapp-2025.