Beagle v. People.
2026 CO 24. No. 24SC154. Sexually Violent Predator Designation—Cruel and Unusual Punishment.
April 27, 2026
The supreme court held that the sexually violent predator (SVP) designation under CRS § 18-3-414.5(1)(a), and its accompanying requirements, do not constitute punishment under the Eighth Amendment to the US Constitution. The court first assessed the SVP designation’s statutory features under the framework in Ellingburg v. United States, 146 S. Ct. 564, 567–68 (2026), and determined that the General Assembly did not intend for the SVP designation to be punishment. From there, the court applied the seven factors enumerated in Kennedy v. Mendoza-Martinez, 372 U.S. 144, 168-69 (1963), and determined that the SVP designation’s punitive effects do not outweigh this nonpunitive intent by the “clearest proof.” Accordingly, the court affirmed the judgment of the court of appeals.