People v. Samson
2012 COA 167
Colo. Ct. App.2012Background
- Samson appeals his convictions for theft-$1,000-$20,000-series and conspiracy to commit theft-$1,000-$20,000-series.
- Prosecution showed Samson, a former roommate of Clark's Market workers, helped himself to groceries on two consecutive days with others’ assistance.
- On March 7, 2010, Samson took $820.49 in goods at DelPapa's checkout without paying.
- On March 8, 2010, Samson took $947.48 in goods at Lopez-Cabello's checkout without paying.
- Juror B, who had close ties to law enforcement, was questioned; the court denied a challenge for cause and Samson exhausted his peremptory challenges.
- Trial proceeded to verdicts of theft and conspiracy, followed by post-trial motions and appellate challenges demonstrating the court’s rulings on the challenged issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of juror-for-cause challenge was error | Samson contends denial was an abuse of discretion. | Samson argues juror's bias required removal for cause. | No abuse of discretion; judge suitably weighed credibility and demeanor. |
| Whether prosecutorial misconduct occurred | Samson asserts closing remarks were improper. | Samson claims remarks inflamed jury passions and misstated evidence. | No prosecutorial misconduct warranting reversal. |
| Whether evidence supports conspiracy conviction without proving value of goods | Samson argues value need be proven for conspiracy. | Samson concedes value matters only for classification, not for conspiracy. | Sufficient evidence supported conspiracy; value need not be proven for the conspiracy element. |
Key Cases Cited
- People v. Wilson, 114 P.3d 19 (Colo. App. 2004) (challenge for cause and impartiality standards)
- People v. Arko, 159 P.3d 713 (Colo. App. 2006) (judicial discretion in voir dire adequacy)
- People v. Ward, 673 P.2d 47 (Colo. App. 1983) (bias and impartiality considerations in juror challenges)
- People v. Jamison, 220 P.3d 992 (Colo. App. 2009) (value as sentencing factor; not element of theft for conspiracy)
- Roberts v. People, 203 P.3d 513 (Colo. 2009) (theft elements and value considerations in conviction)