People v. Ceus.

2026 CO 59. No. 24SC508. Child Abuse Resulting in Death—Instructional Error—Constitutional Harmless Error—Sufficiency of Evidence—“Results In”—"But for” Causation—Proximate Cause—CRS § 18-6-401(1)(a)—CRS § 18-6-401(7)(a)—People v. Dunaway—People v. Beverly.

June 29, 2026

After the prosecution charged Ceus with two murder counts for the deaths of two young girls, the jury returned guilty verdicts on the lesser included offenses of child abuse resulting in death. The supreme court agreed to review this case to consider whether (1) the trial court erred in instructing the jury, (2) any instructional error was constitutionally harmless, and (3) there was sufficient evidence to support the two convictions.

Agreeing with the division, the court first concluded that the trial court should have either used special interrogatories to allow the jury to make distinct findings on whether the child abuse resulted in death or drafted the elemental instructions to require such findings.

But for three reasons, the court parted ways with the division’s conclusion that the error was not constitutionally harmless. First, whether the girls died as a result of the abuse they endured was never meaningfully disputed at trial. Second, the jury instructions and the verdict forms clearly directed the jury to determine whether Ceus had engaged in child abuse that resulted in the girls’ deaths. And third, the evidence that the child abuse resulted in the girls’ deaths was overwhelming.

Finally, like the division, the supreme court rejected Ceus’s sufficiency-of-the-evidence challenge. Viewing the evidence as a whole and in the light most favorable to the People, it is clear that it was both substantial and sufficient to support her guilt beyond a reasonable doubt.

Accordingly, despite agreement with parts of the division’s opinion, the court ultimately reversed the judgment and remanded the case for consideration of Ceus’s remaining claims.