People v. Bruce E. Bagwell

CourtColorado Court of Appeals
DecidedApril 21, 2022
Docket19CA2398
StatusPublished

This text of People v. Bruce E. Bagwell (People v. Bruce E. Bagwell) 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
People v. Bruce E. Bagwell, (Colo. Ct. App. 2022).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY April 21, 2022

2022COA44

No. 19CA2398, People v. Bagwell — Crimes — Murder in the First Degree; Criminal Law — Affirmative Defenses — Consent; Public Health and Environment — End-of-life Options — Colorado End-of-life Options Act

A division of the court of appeals considers whether a

defendant who intentionally kills a consenting, terminally ill victim

may assert a defense of consent under section 18-1-505, C.R.S.

2021. This statute creates an affirmative defense under certain

circumstances in which the victim consents to the defendant’s

conduct or to the injury the defendant causes. Section 18-1-505(2),

however, states: “When conduct is charged to constitute an offense

because it causes or threatens bodily injury, consent to that

conduct or to the infliction of that injury is a defense only if the

bodily injury consented to or threatened by the conduct consented

to is not serious . . . .” The division concludes that death is necessarily a bodily injury

that is serious. The division therefore holds that the defense of

consent is not available to a defendant who intentionally kills a

terminally ill victim who consents to her own death. COLORADO COURT OF APPEALS 2022COA44

Court of Appeals No. 19CA2398 Jefferson County District Court No. 19CR490 Honorable Lily W. Oeffler, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Bruce E. Bagwell,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division II Opinion by JUDGE KUHN Pawar and Rothenberg*, JJ., concur

Announced April 21, 2022

Philip J. Weiser, Attorney General, Elizabeth Rohrbough, 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

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2021. ¶1 Defendant, Bruce E. Bagwell, appeals his conviction of

intentional first degree murder. We affirm.

I. Background

¶2 Bagwell was convicted for killing his terminally ill wife of

thirty-six years. Shortly after Bagwell’s wife was diagnosed with

metastatic lung cancer, her health and quality of life began to

deteriorate. Weeks before Bagwell fatally shot her, his wife

experienced declining cognitive function, lapses in consciousness,

and difficulty walking because the cancer had spread to her brain.

She lost approximately forty pounds and needed a walker or

wheelchair to move around their apartment. Her doctor estimated

she had mere months or weeks to live.

¶3 Hospice care was ordered; a hospice nurse began weekly visits

to the Bagwells’ apartment to attend to Bagwell’s wife and bring her

medication for pain management. Bagwell’s wife, though, elected

not to take these medications or undergo the painful cancer

treatments that might have prolonged her life.

¶4 After she allegedly asked Bagwell to end her life each day for

five days straight, he shot her in the apartment they shared — twice

in her head and once in her chest.

1 ¶5 Shortly before Bagwell fatally shot his wife, he told her sister

he believed his wife would be dead in approximately two weeks. In

the hour after the shooting, Bagwell admitted to his wife’s father,

his wife’s sister, and the arresting officers that he shot his wife

because she asked him to do so to end her suffering. He told law

enforcement that his wife had begged him to shoot her each of the

preceding five days, and he explained that it was a “mercy killing.”

In a videotaped interrogation, Bagwell again admitted to two

detectives that he had killed his wife.

¶6 Bagwell was charged with first degree murder, a class 1 felony

under section 18-3-102(1)(a), (3), C.R.S. 2021. Before trial, he

moved to suppress his statements to the detectives and endorsed

an affirmative defense of consent under section 18-1-505, C.R.S.

2021. The trial court denied Bagwell’s motion to suppress and

precluded him from asserting his wife’s alleged consent to be killed

as a defense. The trial court reasoned that when the General

Assembly intended to create an affirmative defense to homicide, it

did so explicitly.

¶7 Bagwell was convicted and sentenced to life imprisonment. He

challenges both the consent and suppression rulings on appeal.

2 II. Affirmative Defense of Consent

¶8 Section 18-1-505 creates an affirmative defense for criminal

defendants under certain circumstances in which the victim

consents to the defendant inflicting the victim’s injury. Bagwell

contends the trial court erred by denying him this defense to the

first degree murder charge. We conclude that section 18-1-505

does not permit this defense when the victim consents to the

defendant causing the victim’s death.

A. The Affirmative Defense of Consent, First Degree Murder, and Standard of Review

¶9 Section 18-1-505 provides that consent of the victim is an

affirmative defense when, as relevant here, two criteria are met.

§ 18-1-505(1), (2), (4). Subsection (1) makes the defense available if

“the consent negatives an element of the offense or precludes the

infliction of the harm or evil sought to be prevented by the law

defining the offense.” § 18-1-505(1); see Hotsenpiller v. Morris, 2017

COA 95, ¶ 24. But even if subsection (1) is satisfied, subsection

(2) may still preclude the defense. It provides that

[w]hen conduct is charged to constitute an offense because it causes or threatens bodily injury, consent to that conduct or to the infliction of that injury is a defense only if the

3 bodily injury consented to or threatened by the conduct consented to is not serious . . . .

§ 18-1-505(2).

¶ 10 We analyze whether consent can constitute a defense to a

crime in the context of the particular offense and the defendant’s

particular conduct. See Hotsenpiller, ¶ 22 (citing Model Penal Code

§ 2.11 note 1 on General Principles (Am. L. Inst., Official Draft and

Revised Comments 1985)). Bagwell committed first degree murder

if, “[a]fter deliberation and with the intent to cause the death of a

person other than himself, he cause[d] the death of that person.”

§ 18-3-102(1)(a).

¶ 11 Whether section 18-1-505 permits a defense of consent to first

degree murder is a question of statutory interpretation that we

review de novo. See People v. Jones, 2020 CO 45, ¶ 54. If the

defense is available, we also review de novo whether Bagwell

presented sufficient evidence to be entitled to the jury’s

consideration of it. People v. DeGreat, 2018 CO 83, ¶ 16.

¶ 12 “It is the General Assembly’s prerogative to define crimes and

prescribe punishments . . . .” People v. Trujillo, 631 P.2d 146

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People v. Bruce E. Bagwell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-bruce-e-bagwell-coloctapp-2022.