Brown v. People.

2026 CO 51. No. 24SC492. Criminal Law and Procedure—Strict Liability—Habitual Offender.

June 23, 2026

In this case, the supreme court granted certiorari to consider (1) whether People v. Manzo, 144 P.3d 551 (Colo. 2006), is no longer good law or is distinguishable, and whether the trial court reversibly erred and violated Brown’s right to due process because it allowed the jury to convict him of a class 3 felony for leaving the scene of an accident resulting in death without the prosecution proving that he acted with any culpable mental state; and (2) whether Colorado’s prior habitual offender scheme is unconstitutional because it required a judge rather than a jury to make findings of fact that increase a defendant’s sentence, and whether Brown’s adjudication as a habitual offender must be vacated because he was deprived of his right to a jury trial.

The court concluded that (1) Manzo remains good law, and therefore, the trial court did not err or violate Brown’s right to due process in entering judgment for leaving the scene of an accident resulting in death and leaving the scene of an accident resulting in serious bodily injury against him without requiring the prosecution to prove that he acted with any culpable mental state; and (2) the prior Colorado habitual offender scheme was constitutional, and any error in Brown’s adjudication as a habitual offender was harmless beyond a reasonable doubt.

Accordingly, the court affirmed the division’s judgment.