Townsell v. People.

2026 CO 11. No. 23SC924. Postconviction Appointment of Counsel—Ineffective Assistance of Trial Counsel—DNA Evidence.

February 17, 2026

In this case, the supreme court addressed the standard for the appointment of postconviction counsel under both Crim. P. 35(c) and Strickland v. Washington, 466 U.S. 668, 687 (1984).

The court concluded that Townsell’s claim was wholly unfounded because he did not properly allege facts demonstrating prejudice under Strickland. Therefore, the trial court did not err in refusing to appoint postconviction counsel to assist him. Accordingly, the court affirmed the judgment of the court of appeals.