Angelo Emilio Montoya v. the People of the State of Colorado

Summary

The court affirmed Montoya’s convictions and sentences for attempted extreme indifference murder, reckless manslaughter, criminally negligent homicide, and accessory to crime. It held that firing repeatedly into a crowd supported attempted extreme indifference murder, that self-defense did not impose an additional burden on the prosecution beyond proving the offense’s elements, and that Montoya was estopped from challenging the sufficiency of evidence for an accessory conviction he requested as a tactical alternative. The court also held that complicity and accessory to crime are separate offenses and that the convictions did not merge or require concurrent sentences.