Peo v. Archuleta
21CA2097
| Colo. Ct. App. | Sep 5, 2024Background
- Christopher Archuleta was convicted by a jury of two counts of vehicular homicide, multiple counts of vehicular assault, and related offenses after a fatal alcohol- and drug-involved crash on August 25, 2019.
- The collision occurred when Archuleta, after a night of drinking and marijuana use with a friend, attempted to pass another car, resulting in a crash involving a semitruck. One person was killed; several, including Archuleta, were injured.
- Evidence at trial included eyewitness testimony of his drinking, police and expert testimony about his blood alcohol and THC levels, and Archuleta's own admissions.
- Archuleta challenged (1) the admissibility of hospital-obtained BAC evidence, (2) the restitution award to Sentry Insurance, and (3) an erroneous restitution award to another individual that had been withdrawn by prosecutors.
- The trial court sentenced Archuleta to 15 years and ordered restitution payments, including the disputed amounts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of hospital BAC evidence was improper under CRE 703 | BAC evidence was admissible and cumulative to other proof | BAC evidence was inadmissible hearsay and prejudicial | Any error in admission was harmless due to overwhelming other evidence |
| Restitution to Sentry Insurance unsupported by proximate cause | Losses proximately caused by Archuleta's conduct | Prosecution did not prove Archuleta proximately caused the losses | Record supports proximate cause for Sentry Insurance's restitution |
| Correction of withdrawn restitution order | Mittimus should reflect withdrawn restitution for Jose Castro | Mittimus erroneously included withdrawn restitution | Remand to correct mittimus, removing Castro’s restitution award |
Key Cases Cited
- People v. Casias, 2012 COA 117 (harmless error analysis considers cumulative nature and overall strength of evidence)
- Campbell v. People, 2019 CO 66 (harmless error if overwhelming evidence of guilt)
- Tevlin v. People, 715 P.2d 338 (Colo. 1986) (erroneous admission of expert testimony can be harmless given overwhelming guilt)
- Cowen v. People, 2018 CO 96 (restitution limited to losses proximately caused by defendant)
- People v. Steinbeck, 186 P.3d 54 (Colo. App. 2007) (restitution requires proximate cause)