People v. Lopez

2025 COA 73
CourtColorado Court of Appeals
DecidedAugust 28, 2025
Docket23CA0430
StatusPublished
Cited by1 cases

This text of 2025 COA 73 (People v. Lopez) 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. Lopez, 2025 COA 73 (Colo. Ct. App. 2025).

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 August 28, 2025

2025COA73

No. 23CA0430, People v. Lopez — Crimes — Assault in the First Degree — Serious Bodily Injury with a Deadly Weapon; Constitutional Law — Eighth Amendment — Proportionality Review — Per Se Grave or Serious Offenses

A division of the court of appeals holds that first degree

assault (causing serious bodily injury by means of a deadly

weapon), § 18-3-202(1)(a), C.R.S. 2025, remains a per se grave or

serious offense after Wells-Yates v. People, 2019 CO 90M. The

defendant’s twenty-one-year sentence for that offense thus does not

raise an inference of gross disproportionality. The division also

holds that the defendant’s allegations of ineffective assistance of

counsel were insufficient to warrant a hearing under Crim. P. 35(c). COLORADO COURT OF APPEALS 2025COA73

Court of Appeals No. 23CA0430 Jefferson County District Court No. 18CR3242 Honorable Robert Lochary, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Isaiah Josiah Lopez,

Defendant-Appellant.

ORDER AFFIRMED

Division III Opinion by JUDGE SCHOCK Dunn and Brown, JJ., concur

Announced August 28, 2025

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

Megan A. Ring, Colorado State Public Defender, Rachel Z. Geiman, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Isaiah Josiah Lopez, appeals the denial of his

Crim. P. 35(c) motion without a hearing. We affirm. In doing so, we

hold that first degree assault (causing serious bodily injury with a

deadly weapon), § 18-3-202(1)(a), C.R.S. 2025, remains a per se

grave or serious offense after Wells-Yates v. People, 2019 CO 90M.

I. Background

¶2 After an altercation during which he shot the victim in the

knee, Lopez was charged with first degree assault, felony menacing,

child abuse, two counts of reckless endangerment, two counts of

possession of a weapon by a previous offender, three counts of

violating a protective order, and three habitual criminal counts.

¶3 On the morning of the scheduled trial, Lopez pleaded guilty to

first degree assault in exchange for dismissal of the other counts.

Because first degree assault is both an extraordinary risk crime and

a per se crime of violence, Lopez acknowledged that he could be

sentenced to prison for ten to thirty-two years. See § 18-3-

202(1)(a); § 18-1.3-401(1)(a)(V)(A.1), (8)(a)(I), (10)(a), (10)(b)(XII),

C.R.S. 2025; § 18-1.3-406, C.R.S. 2025. The plea agreement

specified that the prosecution made no sentencing concessions.

1 ¶4 The district court sentenced Lopez to twenty-one years in

prison, to run consecutively to twelve-year concurrent prison

sentences he was serving in three other cases. Lopez did not

appeal. Four months later, he moved for sentence reconsideration

under Crim. P. 35(b), which the district court denied.

¶5 Lopez later filed a timely pro se Crim. P. 35(c) motion,

requesting a proportionality review of his sentence and asserting

two other claims for relief. The district court appointed counsel,

who filed two supplements. The supplements incorporated the

three claims Lopez had asserted pro se and added twelve claims of

ineffective assistance of counsel. The prosecution filed a response.

¶6 The district court denied the motion, including the claims

raised in the supplements, without a hearing. As relevant to this

appeal, the court concluded that (1) Lopez’s request for a

proportionality review was not properly brought under Crim.

P. 35(c), and (2) the ineffective assistance of counsel claims were

conclusory and did not allege facts sufficient to support a claim.

2 II. Analysis

¶7 Lopez appeals the district court’s denial of his request for a

proportionality review of his sentence and five of his claims for

ineffective assistance of counsel. We address each in turn.

A. Legal Standard and Standard of Review

¶8 A Crim. P. 35(c) motion may be denied without a hearing when

“the motion and the files and record of the case show to the

satisfaction of the court that the defendant is not entitled to relief.”

Crim. P. 35(c)(3)(IV). This standard is satisfied if (1) the allegations

are bare and conclusory; (2) the allegations, even if true, do not

warrant relief; or (3) the record directly refutes the defendant’s

claims. People v. Duran, 2025 COA 34, ¶ 15. A defendant need not

set forth evidentiary support for the allegations in the motion but

must assert facts that, if true, would provide a basis for relief.

White v. Denver Dist. Ct., 766 P.2d 632, 635 (Colo. 1988).

¶9 We review de novo the district court’s denial of a Crim. P. 35(c)

motion without a hearing. People v. Cali, 2020 CO 20, ¶ 14.

B. Proportionality Claim

¶ 10 We agree with Lopez that the district court erred by concluding

that his request for a proportionality review of his sentence was not

3 a proper Crim. P. 35(c) claim. Although Lopez did not explicitly

assert that his sentence was grossly disproportionate, that was the

substance of his claim. See People v. Collier, 151 P.3d 668, 670

(Colo. App. 2006) (holding that substance of postconviction motion

controls how it is designated). He cited the Eighth Amendment’s

prohibition on grossly disproportionate sentences, see Solem v.

Helm, 463 U.S. 277, 284 (1983), and asserted that he was “entitled

to a proportionality review of his sentence.” Construed liberally,

such a request “is a challenge to the constitutionality of a sentence

under the Eighth Amendment and is properly cognizable under

Crim. P. 35(c).” People v. Castillo, 2022 COA 20, ¶ 38. The district

court therefore should have conducted an abbreviated

proportionality review of Lopez’s sentence.1 See id. at ¶ 36.

¶ 11 But when there is no “need for a refined analysis inquiring

into the details of the specific offense[] . . . , an appellate court is as

well positioned as a [district] court to conduct a proportionality

1 Lopez’s postconviction motion was timely, he did not file a direct

appeal, and this was his first Crim. P. 35(c) motion. The People thus do not argue that the proportionality claim was time barred or successive. See People v. Moore-El, 160 P.3d 393, 395 (Colo. App. 2007) (denying request for proportionality review as time barred).

4 review.” People v. Gaskins, 825 P.2d 30, 37-38 (Colo. 1992),

abrogated on other grounds by Wells-Yates, ¶ 55. That is the case

here.

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Bluebook (online)
2025 COA 73, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-lopez-coloctapp-2025.