The People of the State of Colorado v. Angel Adrian Castro-Velasquez.

CourtSupreme Court of Colorado
DecidedJune 23, 2026
Docket24SC533
StatusPublished

This text of The People of the State of Colorado v. Angel Adrian Castro-Velasquez. (The People of the State of Colorado v. Angel Adrian Castro-Velasquez.) is published on Counsel Stack Legal Research, covering Supreme Court of Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The People of the State of Colorado v. Angel Adrian Castro-Velasquez., (Colo. 2026).

Opinion

2026 CO 49

The People of the State of Colorado, Petitioner v. Angel Adrian Castro-Velasquez. Respondent

No. 24SC533

Supreme Court of Colorado, En Banc

June 23, 2026

Certiorari to the Colorado Court of Appeals Court of Appeals Case No. 22CA2184. Judgment Affirmed.

Attorneys for Petitioner: Philip J. Weiser, Attorney General Gabriel P. Olivares, Senior Assistant Attorney General Caitlin E. Grant, Assistant Attorney General Denver, Colorado

Attorneys for Respondent: Peak Legal Services, LLC Todd Narum Northglenn, Colorado

JUSTICE HOOD delivered the Opinion of the Court, in which CHIEF JUSTICE MARQUEZ, JUSTICE BOATRIGHT, JUSTICE GABRIEL, JUSTICE SAMOUR, JUSTICE BERKENKOTTER, and JUSTICE BLANCO joined.

OPINION

HOOD, JUSTICE

¶1 Crim. P. 41.1 allows law enforcement to obtain a judicial order to collect certain kinds of nontestimonial identification evidence (like the DNA at issue here) without probable cause to believe that the suspect has committed a crime. During the execution of a Rule 41.1 order, officials may not interrogate the suspect. People v. Harris, 762 P.2d 651, 658 (Colo. 1988). If they do, they violate not only the rule but also the Fourth Amendment strictures on which the rule is based.

¶2 In this case, we examine how Colorado courts should determine when this concomitant prohibition on interrogation begins. In other words: When has a law enforcement official commenced execution of a Rule 41.1 order? Because the rule authorizes a narrow intrusion into a suspect's privacy to collect evidence based, in part, on reasonable suspicion to believe that the suspect has committed a crime- the same standard used for an investigatory stop-we hold that the execution of a Rule 41.1 order begins when a reasonable person in the suspect's position would not feel free to leave.

¶3 On the facts presented here, we conclude that the detectives violated Angel Adrian Castro-Velasquez's rights under the Fourth Amendment, and a parallel provision in the Colorado Constitution, by interrogating him after they had seized him to execute a Rule 41.1 order.

I. Facts and Procedural History

¶4 In 2020, an unknown individual broke into Z.H.'s home and assaulted her. The individual fled before the police could arrive. In her initial interviews with law enforcement, Z.H. said that although she didn't recognize the perpetrator during the assault, she thought it could be a classmate she had noticed on the public bus she took to and from school. Z.H. eventually identified this classmate to the police as Castro-Velasquez.

¶5 A detective filed an affidavit seeking a Rule 41.1 order to collect Castro-Velasquez's DNA via buccal swabs. After the court granted the order, the detective contacted Castro-Velasquez and told him that he

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