The People of the State of Colorado v. Jesus Rodriguez-Morelos., 562 P.3d 71

Jesus Rodriguez-Morelos began offering unapproved Certified Nursing Assistant (CNA) classes in Colorado, claiming affiliation with the nonprofit United with Migrants without authorization.
He presented himself as the nonprofit's "Director of Education" and distributed documents bearing the nonprofit's tax-exempt status.
Students paid Rodriguez-Morelos for these classes; complaints later arose about their quality, lack of receipts, and the unauthorized nature of his business.
After investigation, Rodriguez-Morelos was charged with theft, criminal impersonation, and identity theft.
The jury convicted him on all charges, but the Colorado Court of Appeals vacated the identity theft conviction, holding the statute did not apply to use of an entity’s identifying information.
The Colorado Supreme Court granted certiorari to determine whether the identity theft statute covers the unauthorized use of a business entity’s information.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether “personal identifying information” under Colorado’s identity theft statute applies to business entities or only to individuals	The State argued that the statute covers entity as well as individual information, since “of another” refers to both persons and entities	Rodriguez-Morelos argued the statute’s text and definitions limit “personal identifying information” to human beings	Court held the statute’s plain language limits such information to human beings, not organizations

McCoy v. People, 442 P.3d 379 (Colo. 2019) (reciting rules of statutory interpretation for criminal statutes)
People v. Rojas, 450 P.3d 719 (Colo. 2019) (addressing interpretation of statutory language and avoiding surplusage)
St. Vrain Valley Sch. Dist. RE-1J v. A.R.E. ex rel. Loveland, 325 P.3d 1014 (Colo. 2014) (applying the canon noscitur a sociis for statutory interpretation)