Supreme Court of Colorado

Sylvia Johnson

February 6, 2023524 P.3d 36

Summary

The court held that “transfer” in Colorado’s straw-purchaser statute includes temporary transfers and shared use of a firearm, and that the evidence was sufficient to prove Johnson purchased the gun intending to share it with Trujillo. The court further held that Johnson did not waive her constitutional vagueness challenges, but forfeited them by failing to raise them at trial; the omission did not constitute plain error because the governing meaning of “transfer” had not previously been legally defined. The court therefore affirmed the court of appeals.