Gerald Dwayne Lewis, Petitioner v. the People of the State of Colorado, Respondent

Summary

The court affirmed Lewis's separate convictions and sentences for sexual assault and class-two-felony second-degree kidnapping. It held that later federal decisions treating sentencing factors as functionally equivalent to offense elements for jury-trial purposes did not alter the Colorado legislature's intent to authorize cumulative punishment or the statutory strict-elements merger analysis. The court therefore declined to overrule the existing Colorado precedent governing this statutory scheme.