People v. Rojas

2025 COA 25
CourtColorado Court of Appeals
DecidedFebruary 27, 2025
Docket23CA1350
StatusPublished
Cited by1 cases

This text of 2025 COA 25 (People v. Rojas) 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. Rojas, 2025 COA 25 (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 February 27, 2025

2025COA25

No. 23CA1350, People v. Rojas — Criminal Law — Appeals — Resentencing on Remand; Constitutional Law — Fifth Amendment — Double Jeopardy — Fourteenth Amendment — Due Process

In this proceeding, a division of the court of appeals reviews

the propriety of new sentences imposed after the defendant’s

original sentences were vacated on appeal.

First, the division considers whether the district court’s

decision to resentence the defendant conflicted with the mandate

from the previous appeal. Relying on People v.

Hernandez-Escajeda, 2024 COA 111, the division concludes that

the mandate that directed the district court to “impose concurrent

sentences” did not limit the court’s authority to resentence the

defendant. Second, the division concludes that double jeopardy did not

bar the imposition of increased sentences on remand because the

defendant’s original sentences were illegal and subject to review and

revision, and therefore the defendant did not have a legitimate

expectation of finality in them.

Third, the division rejects the defendant’s due process

argument that the new sentences were the product of

vindictiveness. The division holds that when two aggregate

sentences have identical prison terms, the one with a later parole

eligibility date is more severe for due process purposes. But, relying

on Texas v. McCullough, 475 U.S. 134 (1986), the division also

holds that there is no reasonable likelihood that actual

vindictiveness played a part in resentencing when, without more, a

judge who did not impose the original sentences imposes more

severe sentences.

Finally, the division concludes that the district court did not

plainly err by relying on a presentence investigation report that

misclassified the defendant’s prior felony conviction because the

error was not obvious and did not substantially impact the

resentencing proceeding. For all these reasons, the division affirms the new sentences. COLORADO COURT OF APPEALS 2025COA25

Court of Appeals No. 23CA1350 Jefferson County District Court No. 16CR7283 Honorable Robert Lochary, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Thomas Rojas,

Defendant-Appellant.

SENTENCES AFFIRMED

Division IV Opinion by JUDGE YUN Harris and Kuhn, JJ., concur

Announced February 27, 2025

Philip J. Weiser, Attorney General, Majid Yazdi, 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 ¶1 Thomas Rojas appeals the district court’s new sentences

imposed after a division of this court vacated his original sentences.

He contends, among other things, that the district court violated his

right to due process by imposing more severe sentences on remand.

¶2 In People v. Johnson, 2015 CO 70, the Colorado Supreme

Court emphasized that “[d]ue process of law . . . requires that

vindictiveness against a defendant for having successfully attacked

his first conviction must play no part in the sentence he receives

after a new trial.” Id. at ¶ 18 (alterations in original) (quoting North

Carolina v. Pearce, 395 U.S. 711, 725 (1969)). To guard against the

possibility that the “judge may have sought to punish the defendant

for appealing the original decision,” a rebuttable presumption of

vindictiveness arises if “(1) the new sentence on remand is more

severe than the original sentence, and (2) there is a reasonable

likelihood that actual vindictiveness played a part in the

resentencing.” Id. at ¶¶ 18, 22.

¶3 In addressing Rojas’s due process argument, we encounter two

questions of apparent first impression in Colorado. First, are new

sentences with the same aggregate prison term as the original

sentences but a later parole eligibility date more severe for due

1 process purposes? In line with the majority of jurisdictions that

have considered the question, we conclude that they are. Second,

is there a reasonable likelihood of actual vindictiveness when,

without more, a judge who did not impose the original sentences

imposes more severe sentences following a successful appeal?

Relying on the United States Supreme Court’s holdings in Texas v.

McCullough, 475 U.S. 134 (1986), we conclude that there is not.

Accordingly, Rojas’s due process argument fails.

¶4 Because we also reject Rojas’s other contentions, we affirm his

new sentences.

I. Background

¶5 In 2019, a jury convicted Rojas of attempted first degree

murder and first degree assault. The jury found that Rojas caused

serious bodily injury in both crimes, rendering them crimes of

violence.

¶6 At the sentencing hearing, Rojas and the People both agreed

that the district court could impose concurrent sentences. But the

court disagreed and found that, because the convictions were for

crimes of violence, the sentences were required by statute to run

consecutively. The court thus sentenced Rojas to consecutive

2 sentences of eighteen years for attempted murder and fourteen

years for assault, resulting in a total sentence of thirty-two years in

the custody of the Department of Corrections. Thereafter,

anticipating an appeal, the court said, “If for some reason the

appellate court determines that . . . the violent crimes statute does

not apply to this case,” meaning the sentences were not required to

run consecutively, “[this court] will specifically find that a sentence

of the length of [thirty-two] years is necessary and appropriate to

reflect [Rojas’s] conduct here as well as his criminal history.”

¶7 A division of this court affirmed Rojas’s convictions. See

People v. Rojas, (Colo. App. No. 19CA0694, May 26, 2022) (not

published pursuant to C.A.R. 35(e)) (Rojas I). But the division

concluded that the convictions were supported by identical evidence

and therefore their sentences were required to run concurrently. Id.

at ¶¶ 59-63. Accordingly, the division “vacate[d] the sentences and

remand[ed] the case to the [district] court with directions to impose

concurrent sentences.” Id. at ¶ 64.

¶8 On remand, the People asked the district court to reimpose the

thirty-two-year aggregate prison term by resentencing Rojas to

thirty-two years for his attempted murder conviction and running

3 that sentence concurrently to the sentence for his assault

conviction. Rojas, on the other hand, argued that “the mandate of

the appellate court was to impose concurrent sentences” and any

other changes to the sentences would “not comply with the specific

directions of the Court of Appeals.”

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Bluebook (online)
2025 COA 25, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-rojas-coloctapp-2025.