v. Slaughter

2019 COA 27
CourtColorado Court of Appeals
DecidedFebruary 21, 2019
Docket18CA0842, People
StatusPublished
Cited by2 cases

This text of 2019 COA 27 (v. Slaughter) 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. Slaughter, 2019 COA 27 (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 February 21, 2019

2019COA27

No. 18CA0842, People v. Slaughter — Constitutional Law — Colorado Constitution — Equal Protection; Crimes — Assault in the Second Degree; Criminal Law — Sentencing — Mandatory Sentences for Violent Crimes

A division of the court of appeals considers whether charging a

defendant with second degree assault by strangulation under

section 18-3-203(1)(i), C.R.S. 2018, with a crime of violence

sentence enhancer under section 18-1.3-406(2)(a)(I)(A), C.R.S.

2018, violates a defendant’s equal protection rights under the

Colorado Constitution. The division concludes that it does.

Under the Colorado Constitution, if two criminal statutes

provide for different penalties for identical conduct, a person

convicted under the statute with the harsher penalty is denied equal protection of the laws unless there are reasonable differences

or distinctions between the prohibited behaviors.

The division reviews the disparate sentences available for

identical strangulation conduct and concludes that, because there

is no intelligible standard for distinguishing between the prohibited

acts under section 18-3-203(1)(b), on the one hand, and the

prohibited acts under section 18-3-203(1)(i) when charged with a

crime of violence sentence enhancer, on the other hand, the

prosecution’s attempt to charge defendant with the latter

combination violates equal protection. Thus, the prosecution’s

attempt to charge defendant with the combination of section 18-3-

203(1)(i) with a crime of violence sentence enhancer under section

18-1.3-406(2)(a)(I)(A) would be unconstitutional as applied to him. COLORADO COURT OF APPEALS 2019COA27

Court of Appeals No. 18CA0842 Arapahoe County District Court No. 16CR2045 Honorable Andrew C. Baum, Judge

The People of the State of Colorado,

Plaintiff-Appellant,

v.

Darius Javonmarquise Slaughter,

Defendant-Appellee.

ORDER AFFIRMED

Division I Opinion by JUDGE TERRY Taubman and Fox, JJ., concur

Announced February 21, 2019

George H. Brauchler, District Attorney, Jacob Edson, Chief Deputy District Attorney, Centennial, Colorado, for Plaintiff-Appellant

Megan A. Ring, Colorado State Public Defender, Jessica Sommer, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellee ¶1 A prosecutor seeking to charge an accused with felony

strangulation has multiple charging options available under

Colorado criminal statutes.

¶2 The crime can be charged under the first degree assault

statute, section 18-3-202(1)(g), C.R.S. 2018. To obtain a conviction

under that statute, the prosecution would have to prove that the

accused caused serious bodily injury to the victim.

¶3 If the prosecution wants to dispense with the requirement to

prove serious bodily injury, it can charge the accused under the

second degree assault statute, section 18-3-203, C.R.S. 2018. Two

charging options are available for a strangulation crime under that

statute, neither of which would require proof of serious bodily

injury: under subsection (1)(b) or under subsection (1)(i).

¶4 A charge under subsection (1)(b) would require proof of use of

a deadly weapon. Unless charged with a crime of violence sentence

enhancer, a strangulation charge under subsection (1)(i) would not

require proof of use of a deadly weapon.

¶5 As we will discuss, the penalty available for a strangulation

charged under subsection (1)(i) if charged as a crime of violence

under section 18-1.3-406(2)(a)(I)(A), C.R.S. 2018, is substantially

1 more severe than if an accused is charged merely under subsection

(1)(b), even though conviction for both crimes would require proof of

use of a deadly weapon.

¶6 The prosecution charged defendant, Darius Javonmarquise

Slaughter, with strangulation under the second degree assault

statute, section 18-3-203(1)(i). If it were allowed to charge

Slaughter under subsection (1)(i) and also charge a sentence

enhancer under the crime of violence sentencing statute, such

charging would subject him to harsher and disparate sentencing, as

compared with other persons accused of engaging in the same

conduct, based solely on the prosecution’s charging decision. Thus,

his right to equal protection under the Colorado Constitution would

be violated. For that reason, we conclude that the district court did

not err in denying the prosecution’s motion to add a charge under

the crime of violence statute, and we affirm the court’s order

dismissing the added crime of violence charge.

I. Procedural History

¶7 The People filed this interlocutory appeal in accordance with

section 16-12-102(1), C.R.S. 2018, and C.A.R. 4(b)(3). The

prosecution charged Slaughter with second degree assault by

2 strangulation under section 18-3-203(1)(i) for allegedly strangling

the victim with his hands. The People later moved to add a new

count under the crime of violence sentencing statute, section 18-

1.3-406(2)(a)(I)(A), based on their assertion that Slaughter used his

hands as a deadly weapon.

¶8 Though the trial court initially granted the motion, it later

reconsidered that ruling on Slaughter’s motion and dismissed the

charged sentence enhancer. The court reasoned that, as applied to

Slaughter, such a charge violated his right to equal protection of the

laws guaranteed by the Colorado Constitution.

II. Constitutional and Statutory Background

¶9 Under the Fourteenth Amendment to the United States

Constitution, no state shall “deny to any person within its

jurisdiction the equal protection of the laws.” U.S. Const. amend.

XIV, § 1.

¶ 10 In harmony with the Federal Constitution, our supreme court

has held that the right to equal protection of the laws is included

within due process of law as provided in article II, section 25, of the

Colorado Constitution. People v. Marcy, 628 P.2d 69, 83 (Colo.

1981). Even so, distinguishing United States v. Batchelder, 442

3 U.S. 114 (1979), which construed the Federal Constitution, the

court in Marcy emphasized that, under the Colorado Constitution,

“equal protection of the laws requires that statutory classifications

of crimes be based on differences that are real in fact and

reasonably related to the general purposes of criminal legislation.”

Marcy, 628 P.2d at 74. In this respect, equal protection under the

Colorado Constitution is more far-reaching than it is under the

Federal Constitution. Slaughter argues an equal protection

violation only under the Colorado Constitution.

¶ 11 Equal protection of the law assures that those who are

similarly situated will be afforded like treatment. People v. Mozee,

723 P.2d 117, 126 (Colo. 1986). When two criminal statutes

provide different penalties for identical conduct, a defendant is

Free access — add to your briefcase to read the full text and ask questions with AI

Related

v. Maloy
2020 COA 71 (Colorado Court of Appeals, 2020)
v. Lee
2019 COA 130 (Colorado Court of Appeals, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
2019 COA 27, Counsel Stack Legal Research, https://law.counselstack.com/opinion/v-slaughter-coloctapp-2019.