People v. Schmidt

CourtColorado Court of Appeals
DecidedJune 25, 2026
Docket24CA1102
StatusUnpublished

This text of People v. Schmidt (People v. Schmidt) 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. Schmidt, (Colo. Ct. App. 2026).

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 June 25, 2026

2026 COA 52

No. 24CA1102, People v. Schmidt — Crimes — Forgery — Attempt to Influence a Public Servant

A division of the court of appeals disagrees with People v.

Carian, 2017 COA 106, ¶ 26, which held that forgery under

section 18-5-102(1)(d), C.R.S. 2025, applies only to documents filed

“pursuant to a legal mandate.” In addition, the division clarifies

that the crime of attempt to influence a public servant does not

require proof that the public servant had actual authority to act on

the matter under consideration. COLORADO COURT OF APPEALS 2026 COA 52

Court of Appeals No. 24CA1102 Boulder County District Court No. 23CR673 Honorable Stephen E. Howard, Judge Honorable Michael J. Vallejos, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Charles M. Schmidt,

Defendant-Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division V Opinion by JUDGE TOW Welling and Lipinsky, JJ., concur

Announced June 25, 2026

Philip J. Weiser, Attorney General, Rachel Lieb, Assistant Attorney General II, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Christina Van Wagenen, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Charles M. Schmidt, appeals the judgment of

conviction entered on a jury verdict finding him guilty of attempting

to influence a public servant and forgery after he tendered to a

district court judge, in a separate criminal case, a falsified

document purporting to confirm his completion of required useful

public service hours. Among other claims, Schmidt argues that his

forgery conviction must be vacated because the prosecution did not

prove that the falsified document was an instrument filed “pursuant

to a legal mandate” as required by People v. Carian, 2017 COA 106,

¶ 26. Because we disagree with the Carian division’s interpretation

of the relevant statutory language, we reject that claim.

¶2 We also reject Schmidt’s challenge to the sufficiency of the

evidence supporting the conviction for attempt to influence a public

servant. In doing so, we hold — for the first time in a published

appellate decision — that in proving that a defendant attempted to

influence a public servant “concerning any matter which is to be

considered or performed by the public servant,” § 18-8-306, C.R.S.

2025, the prosecution need not prove that the public servant had

actual authority to act on the matter under consideration.

1 ¶3 However, because we conclude that the trial court improperly

precluded Schmidt from introducing certain evidence pertinent to

both charges, we reverse and remand for a new trial.

I. Background

¶4 Schmidt, who had been working as a bounty hunter, was

serving a probation sentence after assaulting someone while trying

to apprehend them. After allegedly violating the terms of his

probation, Schmidt appeared at a probation revocation resentencing

hearing. He submitted a letter to the district court, through his

attorney, attesting that he had completed fifty hours of useful

public service, which had been a condition of his original probation

sentence (the public service letter). Though the public service letter

had a Salvation Army logo on it, it did not appear to be on

letterhead, and the body of the letter was replete with misspellings

and punctuation and grammatical errors. The district court

questioned the validity of the public service letter but reinstated

Schmidt’s probation anyway.

¶5 Following an investigation, the prosecution concluded that

Schmidt had forged the public service letter “to be used to [his]

advantage to convince [t]he [c]ourt that his community service was

2 completed and to bolster his argument to the court regarding his

probation status.” The prosecution charged Schmidt with

attempting to influence a public servant and forgery.

¶6 Schmidt’s defense theory at trial was that he completed his

required public service hours and submitted what he believed to be

valid proof of having done so to the court in the form of his public

service letter. Schmidt’s timeline for completing his public service

hours fell between late 2020 to early 2021 — during the COVID-19

pandemic.

¶7 Schmidt testified that he approached his public service hours

cautiously because he was immunosuppressed. These precautions

included wearing a mask and staying away from others while

completing his work at a Salvation Army food bank. Schmidt also

said that he had back surgery during the same period. Schmidt

testified that he filed a motion with the court to modify his

probation because he was uncertain that he would be able to

complete the public service hours before the court-imposed

deadline due to his physical limitations following his surgery.

¶8 On the morning of the third day of trial, a division of this court

issued an opinion addressing Schmidt’s appeal of his probation

3 resentencing. In People v. Schmidt, (Colo. App. No. 23CA0485, Feb.

22, 2024) (not published pursuant to C.A.R. 35(e)) (Schmidt I), the

division determined that, contrary to the district court’s

understanding, the district court had not stayed Schmidt’s sentence

during the pendency of a prior appeal involving his probation

sentence.1 Thus, his probation sentence had expired before the

probation department moved to revoke it. As a result, the division

concluded that “the district court lacked jurisdiction to revoke

Schmidt’s probation and resentence him based on the new offense

that he allegedly committed after his probation had expired” and

vacated the district court’s order resentencing him to sixty days in

jail and two years of probation. Id., slip op. at ¶¶ 19-21.

¶9 Defense counsel requested a mistrial on the attempt to

influence a public servant and forgery charges, noting that the

“case here is completely premised on a misapplication of the law.”

The district court acknowledged that the opinion raised “legitimate

1 Schmidt had appealed the district court’s denial of his request to

terminate probation early and its order requiring him to serve eight days on electronic home monitoring.

4 issues,” but it nevertheless denied the request and moved forward

with the proceedings. A jury convicted Schmidt on both counts.

¶ 10 Schmidt raises three issues on appeal. He asserts that there

was insufficient evidence to convict him of either charge. He

contends that the trial court2 erred by prohibiting him from

testifying about his own medical diagnoses. And he argues that the

trial court should have permitted him to present witnesses who

would testify regarding his character for truthfulness.

II. Sufficiency of the Evidence

¶ 11 Schmidt contends that the prosecution failed to present

sufficient evidence that he attempted to influence a public servant

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People v. Schmidt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-schmidt-coloctapp-2026.