People v. Medina.
2026 COA 36. No. 24CA2021. Postconviction Remedies—Punishment for Habitual Criminals—Uniform Mandatory Disposition of Detainers Act—Law of the Case Doctrine—New Constitutional Rule.
May 7, 2026
Medina was charged with attempted first degree assault, two counts of felony menacing, possession of a weapon by a previous offender, and seven habitual counts. He subsequently submitted a request under the Uniform Mandatory Disposition of Detainers Act (UMDDA), which allows a person in Department of Corrections (DOC) custody to request the final disposition of any untried charges pending against them in the state. A few weeks before trial, Medina moved to dismiss the charges, arguing that the court lost jurisdiction over the case because it hadn’t gone to trial within the statutory 182-day deadline after he submitted his UMDDA request. The trial court denied the motion, and a jury later convicted Medina on all substantive charges. The trial court then found Medina guilty of all the habitual charges, adjudicated him a habitual criminal, and sentenced him to 44 years in DOC custody. Subsequently, the court of appeals twice denied Medina’s appeals, finding that his right to a speedy trial under the UMDDA had not been violated. Medina then filed two motions at issue here: (1) another motion, under Crim. P. 35(a), to dismiss all charges, again arguing that his UMDDA rights were violated; and (2) a motion to dismiss the habitual charges, arguing that under Erlinger v. United States, 602 U.S. 821, 835 (2024)—announced after the second Medina decision—his conviction on the habitual charges was unconstitutional because a judge, not a jury, had determined that his prior convictions arose out of separate and distinct criminal episodes. The postconviction court summarily denied the first motion and dismissed the second motion on the basis that Erlinger doesn’t apply retroactively.
On appeal, Medina argued that his sentence was illegal because the trial court lacked jurisdiction due to a UMDDA violation. The court applied the law of the case doctrine and declined to address this issue because it had already been resolved by two court divisions.
Medina also contended that his habitual sentence was illegal under Erlinger because a judge, not a jury, determined that his prior convictions arose out of separate and distinct criminal episodes. The court applied the Teague v. Lane, 489 U.S. 288, 310–11 (1989), test to determine whether a new constitutional rule of criminal procedure applies retroactively to cases on collateral review, examining (1) whether Molina’s conviction was final; (2) whether the rule was in fact new; and (3) whether the rule met either of two exceptions to the general bar precluding retroactive application of new rules to cases that were final before the rules were announced. The two exceptions are when the new rule is substantive in nature and when it is a watershed procedural rule. Here, there was no question as to the finality of Medina’s conviction, which became final when the mandate was issued in his direct appeal. Second, Erlinger announced a new rule because it broke new ground; it was neither dictated by preexisting precedent nor apparent to all reasonable jurists. But while Erlinger announced a new constitutional rule, that rule doesn’t meet either Teague exception because it is neither a substantive rule nor a watershed procedural rule. Accordingly, Erlinger cannot be applied retroactively on collateral review. The postconviction court thus properly denied Medina’s Erlinger motion, which was both untimely and successive. Accordingly, the court didn’t address the merits of Medina’s claim challenging his habitual sentence.
The orders were affirmed.