People v. Sandoval-Candelaria
2014 CO 21
| Colo. | 2014Background
- Sandoval/Candelaria charged with first-degree murder but convicted of manslaughter for killing his wife.
- At sentencing, court delayed sentencing for six months and seven days to await disposition of an unrelated on-bond felony case.
- Defendant pleaded guilty in the on-bond case before manslaughter sentencing.
- At rescheduled sentencing, court concluded the on-bond conviction warranted an aggravated-range sentence and imposed 12 years.
- Court of appeals held the delay was unreasonable under Crim. P. 32(b) and that it violated speedy sentencing.
- Supreme Court reversed, holding the delay was legally justifiable to further the General Assembly’s intent to punish on-bond recidivists and not presumptively prejudicial; remanded to reinstate 12-year sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the six-month delay ‘unreasonable’ under Crim. P. 32(b)? | Sandoval argued delay served no legally justifiable purpose. | People argued delay furthered statutory intent to sentence recidivists within aggravated range. | No; delay was legally justifiable and reasonable. |
| Did the delay violate the defendant’s right to speedy sentencing?</br> | Sandoval claimed constitutional speedy-sentencing violation. | People contended no presumptive prejudice from the delay. | Not presumptively prejudicial; no further inquiry required. |
| Did 18-1.3-401(9)(a) apply to justify the sentence enhancement delayed by the on-bond disposition? | Court’s timing should not affect applicability; delay could trigger enhancement. | Delay appropriately allowed determination of eligibility for enhancement. | Statutory intent to punish on-bond recidivists affirmed; delay legally justifiable. |
| Should the case be reviewed under the standard for Crim. P. 32(b) and Barker v. Wingo? | Plaintiff contends Barker factors show prejudice and delay is unreasonable. | Delay not presumptively prejudicial; Barker factors not triggered. | Delay not unreasonable; no speedy-sentencing violation; remand for sentence reinstatement. |
Key Cases Cited
- Gallagher v. District Court, 632 P.2d 1009 (Colo.1981) (set framework that delay must have legally justifiable reason under Crim. P. 32(b))
- Moody v. Corsentino, 843 P.2d 1355 (Colo.1993) (assumes speedy sentencing extends through sentencing; Barker-type analysis)
- Pollard v. United States, 352 U.S. 354 (U.S. 1957) (assumption that right to speedy trial extends through sentencing (assumed))
- Doggett v. United States, 505 U.S. 647 (U.S. 1992) (presumptive prejudice threshold; trigger for Barker inquiry depends on delay length)
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (ad hoc balancing factors for speedy-trial/sentencing claims)
- Wells v. Petsock, 941 F.2d 253 (3d Cir.1991) (discusses scheduling discretion and docket management)
- United States v. Ray, 578 F.3d 184 (2d Cir.2019) (speedy sentencing presumed not extending through sentencing (cited by district court))
- People v. Hunter, 2013 CO 48 (Colo.2013) (cites interpretive approach to statutory construction for sentencing)