Hupke v. People.

2026 CO 31. No. 24SC513. Statutory Construction—Attempt to Influence a Public Servant.

May 18, 2026

CRS § 18-8-306 criminalizes attempts to influence a public servant’s actions “by means of deceit.” The supreme court held that this phrase encompasses a defendant’s use of a third party to engage in deception. The court observed that the plain and ordinary meaning of the word “deceit” is broad and concluded that it encompasses using a third party to convey false information. Therefore, the court held that a defendant violates § 18-8-306 when the defendant uses a third party to convey false information in an effort to influence a public servant’s actions and the false information actually reaches the public servant.

The court further concluded that the evidence at trial, viewed in the light most favorable to the prosecution, was sufficient to support Hupke’s conviction under § 18-8-306. Accordingly, the court affirmed the judgment of the court of appeals.