v. Neckel

2019 COA 69
CourtColorado Court of Appeals
DecidedMay 9, 2019
Docket17CA0279, People
StatusPublished
Cited by1 cases

This text of 2019 COA 69 (v. Neckel) 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
v. Neckel, 2019 COA 69 (Colo. Ct. App. 2019).

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 May 9, 2019

2019COA69

No. 17CA0279, People v. Neckel — Civil Procedure — Process — Process Servers — Execution of Public Duty; Crimes — Trespass

A division of the court of appeals considers whether “No

Trespassing” signs render a process server a trespasser the moment

he enters a property to effectuate process. Relying in part on the

reasoning in Florida v. Jardines, 569 U.S. 1, 8 (2013), the division

concludes that a sign alone does not revoke the implied license to

approach the front door of a home. Although the implied license

may be revoked, a process server’s conduct remains statutorily

privileged to the extent that it is consistent with the laws governing

the execution of legal process. Therefore, a process server’s entry

onto a property with “No Trespassing” signs does not automatically

render him a trespasser. The division further rejects defendant’s contentions that the

trial court erroneously rejected his tendered jury instruction

concerning the duty to retreat as it applies to the affirmative

defense of defense of premises; and that the trial court should have

provided supplemental instructions to the jury defining “unlawful

trespass” in the context of the affirmative defense of defense of

premises.

Accordingly, the division affirms the judgment. COLORADO COURT OF APPEALS 2019COA69

Court of Appeals No. 17CA0279 Larimer County District Court No. 15CR1844 Honorable Daniel J. Kaup, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Eric Alexus Neckel,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division V Opinion by JUDGE GROVE Terry and J. Jones, JJ., concur

Announced May 9, 2019

Philip J. Weiser, Attorney General, Gabriel P. Olivares, Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Alan M. Lijewski, Alternate Defense Counsel, Longmont, Colorado, for Defendant-Appellant ¶1 Defendant, Eric Alexus Neckel, appeals his convictions for

felony menacing and second degree criminal tampering. He

contends the trial court erred by not sua sponte correcting alleged

misstatements by the victim and the prosecutor and by rejecting

defense-tendered jury instructions. We affirm.

I. Background

¶2 The People charged Neckel with felony menacing and second

degree criminal tampering after he threatened a process server with

a lead pipe and then jacked up the process server’s car, preventing

him from leaving.

¶3 Neckel lives in a rural area of Larimer County. His house is

set back approximately a quarter mile from a county road. A long

U-shaped driveway circles behind the house and meets the road at

two points. Neither driveway entrance is gated, and there is no

fencing along the road. There is, however, a small “No Trespassing”

sign nailed to a telephone pole near one entrance. Another similar

sign is on the side of a barn behind the house.

¶4 A process server (the victim) drove to Neckel’s house one

afternoon to serve Neckel with some papers. He parked in the

1 driveway and knocked on the door. Hearing no immediate

response, the victim left a note with his contact information and

turned away. As the victim was walking back toward his car,

Neckel opened the door and asked the victim if he had “ever been

killed.” The victim answered “no.” Neckel then asked the victim if

he had “ever been shot.” The victim said “not yet.”1

¶5 The victim tried to tell Neckel why he was there and asked

Neckel to confirm his identity. Rather than responding directly,

Neckel began berating the victim, telling him that he had no right to

be there and was trespassing, and demanding that the victim get off

his land. When the victim asked Neckel to identify himself so that

he could confirm service of the papers, Neckel picked up a large

metal pipe and raised it over his head. The victim said, “[I]f you do

that, it’s murder.” When Neckel said “it’s coming on three,” the

victim retreated behind his car. He then told Neckel that he was

serving him by refusal, but Neckel began circling the car with the

1 Immediately after this exchange, the victim turned on a voice recorder. Audio of the remainder of the interaction was captured on that device, on contemporaneous 911 recordings, or both. 2 pipe. The victim kept the car between himself and Neckel, but after

a few circuits Neckel placed a hydraulic jack under the front wheels

of the victim’s car and lifted it off the ground.

¶6 Both men called 911 in the midst of this slow-motion chase.

The victim reported that Neckel had threatened him with “a three

foot piece of pipe” and had put a jack under his car, thus

preventing him from leaving the property. Neckel called 911 four

times. During the first call he and the 911 operator had the

following exchange:

Neckel: He’s on private property and I’m going to neutralize the threat right now.

911 Operator: No, you can’t do that.

Neckel: Would you like me to ahh, render him incompetent? Would you like me to shoot him?

911 Operator: No, I want you to go inside and shut and lock the door and wait for a deputy.

Neckel: That I won’t do. He’s in front of my house —

911 Operator: OK —

Neckel: — and he has no business.

3 911 Operator: OK. Are you behind on any payments? Why is he there?

Neckel: It matters not. . . .

The 911 operator repeatedly told Neckel to go inside, although it is

not clear from the record whether he did so before the victim left.

Nonetheless, at some point during the 911 calls, the victim’s vehicle

was released from the jack and he left the area to meet the police.

¶7 Neckel was charged with one count of felony menacing for

threatening the victim with the metal pipe and one count of second

degree criminal tampering for using the jack to prevent the victim

from leaving in his car. A jury found Neckel guilty of both counts.

II. Analysis

¶8 Neckel raises three contentions on appeal. First, he argues

that the trial court committed plain error when it failed to sua

sponte correct four alleged misstatements by the victim and the

prosecutor regarding the law of trespass. Second, he contends that

the trial court erroneously rejected his tendered jury instruction

concerning the duty to retreat as it applies to the affirmative

defense of defense of premises. And last, he asserts that the trial

court erroneously refused his supplemental instructions defining 4 “unlawful trespass” in the context of the affirmative defense of

defense of premises. We address and reject each argument in turn.

A. The Trial Court Did Not Err by Failing to Sua Sponte Correct Alleged Misstatements of Law by the Victim and the Prosecutor

¶9 Neckel asserts that the trial court committed plain error when

it failed to correct what he contends were a total of “four

misstatements regarding the law of trespass” made by the victim

while testifying and the prosecutor during closing arguments. We

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2019 COA 69, Counsel Stack Legal Research, https://law.counselstack.com/opinion/v-neckel-coloctapp-2019.