Garcia v. People.

2023 CO 30. No. 21SC564. Jury Instruction—First-Degree Murder—Extreme Indifference Murder—Universal Malice.

June 5, 2023

The Supreme Court concluded that the trial court did not err by refusing to provide Garcia’s requested jury instruction defining the term “universal malice,” which  appears among the statutory elements for extreme-indifference first-degree murder. The Court reasoned that the plain language of the statute should be sufficiently clear to a reasonable person of common intelligence.