People v. Palacios

2018 COA 6, 419 P.3d 1014
CourtColorado Court of Appeals
DecidedJanuary 25, 2018
Docket15CA1395
StatusPublished
Cited by482 cases

This text of 2018 COA 6 (People v. Palacios) 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. Palacios, 2018 COA 6, 419 P.3d 1014 (Colo. Ct. App. 2018).

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 January 25, 2018

2018COA6

No. 15CA1395 People v. Palacios — Criminal Law — Fifth Amendment — Pre-Trial Identification; Evidence — Demonstrative Evidence — Admissibility

In this criminal case, a division of the court of appeals first

concludes that the police’s placement of a suspect’s photograph in a

particular position in a photo array, after the witness had selected a

photograph in that position from a different photo array, does not

render the identification procedure unduly suggestive. Accordingly,

the division affirms the district court’s denial of the defendant’s

motion to suppress the identification evidence.

Next, the division concludes that the admission of any

demonstrative aid, including the full-size mock-up of the crime

scene at issue in this case, is governed by the four-part test

articulated in People v. Douglas, 2016 COA 59. To be admissible under that test, the demonstrative aid must be authenticated, it

must be relevant, it must be a fair and accurate representation of

the evidence to which it relates, and its probative value must not be

substantially outweighed by the danger of unfair prejudice.

Because the demonstrative aid satisfied the test for

admissibility, the division concludes that the district court did not

abuse its discretion in allowing the prosecution to use the

demonstrative aid during certain witness testimony and closing

argument. COLORADO COURT OF APPEALS 2018COA6

Court of Appeals No. 15CA1395 Jefferson County District Court No. 13CR2977 Honorable Todd L. Vriesman, Judge Honorable Christopher J. Munch, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Jose Luis Palacios,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division VI Opinion by JUDGE HARRIS Terry and Plank*, JJ., concur

Announced January 25, 2018

Cynthia H. Coffman, Attorney General, Melissa D. Allen, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Suzan Trinh Almony, Alternate Defense Counsel, Broomfield, 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. 2017. ¶1 Defendant, Jose L. Palacios, was convicted of felony murder,

aggravated robbery, and other offenses after a drug-deal-turned-

robbery ended in the shooting death of the victim by Palacios’s

accomplice.

¶2 On appeal, Palacios challenges his convictions on two

grounds. First, he argues that the court erred in failing to suppress

a witness’s identification as the product of an impermissibly

suggestive identification procedure. Second, he argues that the

court erred in allowing the prosecution to use a full-size

reconstructed model or “mock-up” of the crime scene during two

prosecution witnesses’ testimony and again during closing

argument. We reject both arguments and therefore affirm.

I. Motion to Suppress Identification

¶3 We begin with some factual background relevant to the motion

to suppress.

¶4 The murder occurred in a detached garage, which the victim

used as his residence. Two witnesses were present in the garage at

the time of the crime: the victim’s marijuana supplier and the

victim’s girlfriend.

1 ¶5 On the night of the murder, police presented the girlfriend

with a photo array. By this time, police knew that two perpetrators

had committed the crime and they had identified the accomplice as

a suspect. The array included a photo of the accomplice in position

no. 1, and five “filler” photos. The girlfriend selected photograph no.

1 as the accomplice and a filler photograph in position no. 3 as

possibly depicting the second perpetrator.1

¶6 Two days later, police showed the girlfriend another photo

array, in an effort to identify the true second perpetrator. The array

included a photograph of a suspect — not Palacios — in position

no. 3, and five filler photographs. The girlfriend selected a filler

photograph in position no. 5 as a photo of the second perpetrator.

¶7 Police soon learned that Palacios was likely the second

perpetrator. So they showed the girlfriend a third photo array, this

time with a photograph of Palacios in position no. 3, and five filler

1 The record was inconsistent regarding the girlfriend’s initial identifications. In the affidavit for an arrest warrant, the officer stated that the girlfriend identified the accomplice as the person in either photograph no. 1 or photograph no. 3. At the suppression hearing, however, a different police officer testified that the girlfriend selected photograph no. 1 as the accomplice and photograph no. 3 (a filler) as the defendant. The inconsistency does not affect our analysis. 2 photographs. The girlfriend identified Palacios as the second

perpetrator.

¶8 Palacios filed a motion to suppress the girlfriend’s out-of-court

identification and to exclude any subsequent in-court identification.

He contended that the police had “induced” the girlfriend’s

identification of Palacios by “putting the suspect in the same

position as the filler that had already been selected.” The court

denied the motion, reasoning that because the girlfriend had

previously selected photos in position nos. 1, 3, and 5, simply

placing Palacios’s photo in position no. 3 did not render the array

impermissibly suggestive.

¶9 On appeal, Palacios reasserts his argument that the final

photo array was impermissibly suggestive because his photo was

placed in position no. 3, after the girlfriend had selected a filler

photograph in position no. 3 from the initial array.

¶ 10 The constitutionality of pretrial identification procedures is a

mixed question of law and fact. People v. Borghesi, 66 P.3d 93, 104

(Colo. 2003). While we defer to the district court’s findings of fact,

we may give different weight to those facts and reach a different

conclusion. Id.

3 ¶ 11 Our review of an identification procedure entails a two-part

analysis. Bernal v. People, 44 P.3d 184, 191 (Colo. 2002). First, we

must decide whether the identification procedure was unduly

suggestive, which the defendant has the burden of proving. Id.

Second, if the identification procedure was unduly suggestive, the

burden shifts to the prosecution to show that the identification was

nevertheless reliable under the totality of the circumstances. Id.

¶ 12 We look to various factors to determine whether a pretrial

photographic identification procedure was impermissibly

suggestive, including the size of the photo array, the manner of its

presentation by the officers, and the details of the photographs

themselves. Id. Palacios does not challenge the size of the array or

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Bluebook (online)
2018 COA 6, 419 P.3d 1014, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-palacios-coloctapp-2018.