People v. Coulier.
2026 COA 45. No. 24CA1716. Impersonating a Police Officer—Definition of “an Act.”
June 4, 2026
Coulier and Lopez made an agreement for Coulier to purchase an inoperable vehicle from Lopez. They agreed that payment and title would be exchanged once the vehicle became operable. Lopez gave Coulier the keys, and Coulier began making repairs that same day. But without consulting Lopez, Coulier moved the vehicle to his property down the street to continue the repairs. When Lopez discovered the vehicle missing the next day, she called the police and reported it stolen. Meanwhile, Coulier fixed the vehicle and gave the car to his son, who was later stopped by police officers for driving a stolen vehicle. Coulier went to Lopez’s house to sort out the matter, but Lopez refused to talk to him. Coulier then called Lopez, identifying himself as “Detective Rich of the Colorado Springs Police Department” and requesting that Lopez let the “detective” bring Coulier to her house to talk about the stolen vehicle. Lopez did not believe the call was from the police and hung up. Lopez later contacted police about the incident. An officer contacted Coulier, who confirmed that he had identified himself as “Detective Rich.” Coulier was charged with one count of motor vehicle theft and one count of impersonating a peace officer. The jury acquitted Coulier of motor vehicle theft but found him guilty of impersonating a peace officer.
On appeal, Coulier contended that the impersonation statute requires an overt act and that there was insufficient evidence of such to support his conviction. CRS § 18-8-112(1) states that “[a] person who falsely pretends to be a peace officer and performs an act in that pretended capacity commits impersonating a peace officer.” But the word “act” is not defined by statute. The court of appeals concluded that “an act” may be any conduct performed while in the pretended capacity and that this interpretation comports with federal case law requiring a defendant to engage in conduct that is more than mere bravado, puffery, or bragging. Here, Coulier satisfied the first element of the statute, pretending to be a peace officer, when he called Lopez and identified himself as a police detective. Then, when he tried to have Lopez meet with him at her house to resolve the matter, this constituted an act satisfying the second statutory element. Accordingly, sufficient evidence supported Coulier’s conviction.
The judgment was affirmed.