Supreme Court of Colorado
v. People
November 4, 20192019 CO 89
Summary
The court held that possession of schedule I and II controlled substances and theft are not per se grave or serious offenses for purposes of abbreviated proportionality review. It further held that courts must consider relevant post-offense legislative amendments, even when those amendments are not retroactive. Because the lower courts applied contrary rules and additional factual findings were necessary, the judgment was reversed and the case was remanded for a new proportionality review.