Jarrod Ralph Rutter, Petitioner v. the People of the State of Colorado, Respondent

Summary

The court affirmed the ninety-six-year habitual-criminal sentence, holding that the triggering offense of manufacturing methamphetamine remained grave or serious despite later legislative changes concerning drug use and possession. Because the triggering offense had not been reclassified, the court declined to decide whether courts may consider subsequent legislative changes during abbreviated proportionality review and concluded that the sentence was not grossly disproportionate. Justice Gabriel, dissenting and joined by Justices Márquez and Hood, would have considered the legislative changes and remanded for a new abbreviated proportionality review.