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Peo v. Juranek - Colorado Court of Appeals Judgment Affirmed

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Filed March 19th, 2026
Detected March 24th, 2026
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Summary

The Colorado Court of Appeals affirmed a judgment of conviction against Maurice Juranek. Juranek appealed his convictions for failing to stop at a stop sign, vehicular eluding, and obstructing a peace officer, arguing insufficient evidence and errors in expert testimony and prosecutorial misconduct. The court found no reversible error.

What changed

The Colorado Court of Appeals has affirmed the conviction of Maurice Juranek in case number 23CA1748. Juranek was convicted of failing to stop at a stop sign, vehicular eluding, and obstructing a peace officer following a traffic infraction, vehicular pursuit, and foot chase. He appealed, raising arguments regarding insufficient evidence for vehicular eluding, improper expert testimony, prosecutorial misconduct during closing arguments, and the cumulative effect of these alleged errors.

The appellate court rejected Juranek's arguments and affirmed the trial court's judgment. This decision means the conviction stands, and Juranek must abide by the original sentencing and penalties imposed. For legal professionals and compliance officers involved in criminal appeals, this case serves as an example of how appellate courts review evidence sufficiency and procedural errors in criminal proceedings.

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March 19, 2026 Get Citation Alerts Download PDF Add Note

Peo v. Juranek

Colorado Court of Appeals

Combined Opinion

23CA1748 Peo v Juranek 03-19-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 23CA1748
El Paso County District Court No. 23CR2020
Honorable William Bain, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Maurice Juranek,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division VII
Opinion by JUDGE GOMEZ
Pawar and Johnson, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e)
Announced March 19, 2026

Philip J. Weiser, Attorney General, Grant R. Fevurly, Senior Assistant Attorney
General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Daniel J. Sequeira, Deputy
State Public Defender, Denver, Colorado, for Defendant-Appellant
¶1 Following a traffic infraction, a vehicular pursuit, and a foot

chase, Maurice Juranek was charged with and convicted of failing

to stop at a stop sign, vehicular eluding, and obstructing a peace

officer. Juranek now appeals the judgment of conviction.

¶2 On appeal, Juranek argues that there is insufficient evidence

to support his conviction on the vehicular eluding charge. He also

argues that (1) the trial court erred by allowing improper expert

testimony from a police officer at trial; (2) the trial court erred by

allowing the prosecutor to engage in misconduct during closing

argument; and (3) the cumulative effect of these errors requires

reversal. We reject his arguments and affirm the judgment.

I. Background

¶3 One afternoon, Officer Gene Drake was monitoring traffic in a

residential area in a marked Colorado Springs Police Department

(CSPD) vehicle. He saw a sedan, closely followed by a pickup truck,

approaching a stop sign on a two-lane road. After the sedan came

to a stop, the truck stopped suddenly just behind it. The truck

then followed the sedan through the intersection without stopping.

¶4 Officer Drake activated his overhead lights (which in turn

activated his body-worn camera) and began following the truck. At

1
first, the truck continued down the road without any noticeable

reaction from the driver, so Officer Drake activated his sirens. The

truck then accelerated, and Officer Drake notified dispatch that he

was in pursuit of the truck and gave them the license plate number.

The truck passed the sedan and then went around another vehicle

that was stopped at a stop sign. It then made a turn and continued

out of sight. At that point, Officer Drake terminated the pursuit,

which had lasted roughly fifteen seconds.

¶5 About half an hour later, Officer Drake, responding to an

investigative lead based on the truck’s license plate number, arrived

at a nearby townhome complex. There, he saw a pickup truck with

the same license plates. As he approached, a man standing by the

truck, later identified as Juranek, ran off. Officer Drake again

activated his body-worn camera and chased Juranek through the

townhome complex, shouting for him to stop. Officer Drake

eventually apprehended Juranek and ordered him to stay put.

Juranek again tried to run, so Officer Drake tased him, causing him

to fall and hit his face on the concrete. Officer Drake then arrested

him. A bystander filmed part of these events on his phone.

2
¶6 An ambulance took Juranek to a hospital to treat the injuries

he suffered when he fell. Another CSPD officer reported to the

hospital to take custody of Juranek. There, Juranek asked to call

his girlfriend, which the officer allowed him to do. A portion of the

call was recorded by the officer’s body camera. Juranek’s girlfriend

told Juranek that she’d heard he “took off” from the police. He

responded, “I just didn’t know they were behind me and I went

through the stoplight and I left. . . . I pulled over and I thought

they were after the car in front of me or whatever and I just left.”

¶7 At trial, Officer Drake testified, and video footage from the two

officers’ body cameras and the bystander’s cell phone was admitted.

Juranek declined to testify.

¶8 Juranek now appeals.

II. Sufficiency of the Evidence

¶9 Juranek first contends that there is insufficient evidence to

support his conviction for vehicular eluding. We disagree.

¶ 10 We review claims challenging the sufficiency of the evidence

de novo. McCoy v. People, 2019 CO 44, ¶ 63. In doing so, we

consider whether the evidence, viewed in the light most favorable to

the prosecution, supports a reasonable conclusion that the

3
defendant is guilty beyond a reasonable doubt. People v. Tomaske,

2022 COA 52, ¶ 17. However, we “may not serve as a thirteenth

juror and consider whether [we] might have reached a different

conclusion than the jury.” People v. Harrison, 2020 CO 57, ¶ 33.

Thus, we will disturb the verdict only if, despite drawing every

reasonable inference in favor of the prosecution, the record is

unsubstantial and insufficient to support a guilty verdict beyond a

reasonable doubt. Thomas v. People, 2021 CO 84, ¶ 10.

¶ 11 The vehicular eluding statute provides:

Any person who, while operating a motor
vehicle, knowingly eludes or attempts to elude
a peace officer also operating a motor vehicle,
and who knows or reasonably should know
that he . . . is being pursued by said peace
officer, and who operates his . . . vehicle in a
reckless manner, commits vehicular eluding.

§ 18-9-116.5(1), C.R.S. 2025.

¶ 12 Juranek asserts that the evidence doesn’t support findings

that he (1) knew or reasonably should have known he was being

pursued by a peace officer; (2) knowingly eluded or attempted to

elude the officer; or (3) operated his vehicle in a reckless manner.

¶ 13 As to the first contested fact, the evidence supports a finding

that Juranek knew or should have known he was being pursued.

4
Officer Drake testified that after he activated his lights and then his

sirens on his CSPD vehicle, the truck accelerated and passed the

sedan in front of it as well as another car before turning and driving

out of sight, suggesting that the driver was aware of his pursuit.

See People v. Fury, 872 P.2d 1280, 1283 (Colo. App. 1993) (proof of

the use of police vehicle lights or sirens may assist in establishing a

defendant’s knowledge that they were being pursued). Also, when

Juranek later spoke with his girlfriend, he indicated his belief that

the officer was “after” someone, though he insisted he believed it

was the car in front of him. And Juranek’s flight when Officer

Drake approached him at the townhome complex suggests his

awareness that he’d done something wrong. See People v. Gee,

2015 COA 151, ¶ 26 (“Evidence of a defendant’s flight may be

relevant to show consciousness of guilt . . . .” (quoting People v.

Perry, 68 P.3d 472, 475 (Colo. App. 2002))).

¶ 14 This same evidence also supports a finding that Juranek

knowingly eluded or attempted to elude Officer Drake. In

particular, Officer Drake’s testimony suggests that although the

truck’s driver didn’t immediately react when he activated his

overhead lights, once he activated his sirens, the truck accelerated

5
and drove around other cars to get away. And, contrary to

Juranek’s later statement to his girlfriend, neither Officer Drake’s

testimony nor the body camera footage indicates that the truck ever

stopped, pulled over, or waited for Officer Drake to go by.

¶ 15 Finally, there is sufficient evidence to support a finding that

Juranek operated his vehicle in a reckless manner. See § 18-1-

501(8), C.R.S. 2025 (“A person acts recklessly when he consciously

disregards a substantial and unjustifiable risk that a result will

occur or that a circumstance exists.”). Officer Drake testified that

Juranek accelerated and drove into the oncoming traffic lane to get

around the sedan ahead of him. He also testified that Juranek then

went into the oncoming traffic lane again to get around another

vehicle that was stopped at a stop sign, after which Juranek made a

wide turn around and in front of that vehicle to make a right turn.

And Juranek did all this in a residential area.

¶ 16 Thus, drawing every reasonable inference in favor of the

prosecution, we cannot say that the record is unsubstantial or

insufficient to support a guilty verdict beyond a reasonable doubt.

See Thomas, ¶ 10.

6
III. Police Officer Testimony

¶ 17 Juranek also contends that the trial court erred by allowing

Officer Drake to give improper expert testimony under the guise of

lay testimony. We’re not persuaded.

A. Additional Background

¶ 18 During his direct examination, Officer Drake gave the following

testimony regarding CSPD’s pursuit policy:

[P]er [CSPD’s] pursuit policy, we don’t engage
in vehicle chases unless it’s involved in a
violent felony. . . . It’s intensely dangerous to
chase other vehicles and potentially in public
places where you or a neighborhood full of
children or whatever is driving . . . so by policy
effectively we don’t chase unless it’s a violent
felony.

We do call out that someone is fleeing. And
then we make not the grand motion but a
noticeable motion to indicate to the other
people that we are not pursuing. For instance,
pulling off into a cul-de-sac, turning off your
lights so that the person that is fleeing you
ideally will then realize that you’re no longer
pursuing them and they stop their very
dangerous actions.

¶ 19 Later, on cross-examination, Officer Drake said,

[T]he policy is pretty distinct about violent
felonies. It’s dangerous for anyone to drive a
car recklessly, like people do when they flee
police. So serious bodily injury is definitely a
consideration.

7
¶ 20 Then, on redirect, the prosecutor engaged Officer Drake in the

following line of questioning regarding the policy:

[Prosecutor]: So it is a policy of CSPD that
vehicular pursuits present hazards and life-
threatening risks?

[Prosecutor]: And you as an officer have the
duty to balance whether apprehension is more
important than your safety or the public’s
safety?

[Prosecutor]: It’s also the policy of CSPD to
protect the public from unnecessary risk by
weighing the need to apprehend a subject who
flees from law enforcement against the risk of
pursuit to the public, correct?

Officer Drake: Yes, absolutely.

....

[Prosecutor]: [T]here are limitations on when
you can engage in pursuits, correct?

[Prosecutor]: You’re only allowed to engage in a
vehicle pursuit when you reasonably believe
that the need to immediately apprehend the
driver outweighs the risk the pursuit poses to
the public and the officer?

8
[Prosecutor]: And you also have to consider
whether it’s necessary to effect an arrest
because that person has committed or is
committing a violent felony, correct?

[Prosecutor]: And you reference that itself in
your direct testimony when I was asking you
questions earlier this afternoon?

[Prosecutor]: The policy goes on to say that
“vehicular eluding in and of itself is not a
violent felony for the purposes of this policy,”
you’re aware of that?

[Prosecutor]: The policy itself talks about
considerations that you as an officer must
make the decision on when deciding whether
to engage in a pursuit. Can you tick off some
of those things that you have to make that
decision on in a split second?

Officer Drake: So generally safety for the
public is just No. 1 every single time. I would
not start a pursuit in a busy parking lot like a
Walmart. I wouldn’t start one near a school
zone. In a residential zone where kids are on
bikes playing on the street or something like
that. I wouldn’t do anything in a rush hour.
There’s a distinct difference between starting a
pursuit at 3 a.m. on Powers when there’s two
cars up and down Powers and 5 p.m. on
Academy at Austin Bluffs and Academy right
as the schools are letting out or 4 p.m. as the
schools are letting out.

9
So in this situation where even if it’s not a
particular busy hour on the road, it’s still a
residential zone. There are still other vehicles
in the area. And, again, we don’t have the
violent felony to justify risking myself, anyone
else on the road, or even the suspect because
it is a genuine danger to get in a car chase.

....

[Prosecutor]: Do you have to obtain approval
from a supervisor to continue a pursuit?

Officer Drake: So the decision to initiate a
pursuit is on the patrol officer. And a
supervisor will decide whether or not to
continue pursuit or just will completely flat out
deny a pursuit if you call it out.

¶ 21 Finally, Officer Drake testified as follows about best practices

relating to foot pursuits:

[A]s a general practice, it’s best to try to
minimize injury as much as humanly possible.
If I — instead of issuing a taser strike on
someone or jumping on them or hitting them
or anything along these lines, you almost
universally — unless we don’t have the time to
do so, it’s good practice to — well, it’s actually
a legal requirement.

It’s really good practice to give people every
chance possible to comply. So if I give
someone a simple command like, “Lay on the
ground,” and they don’t respond or don’t follow
that instruction, then I can understand that
they are not complying. You know, then you
move to the next step . . . .

10
¶ 22 Defense counsel didn’t object to any of this testimony.

B. Discussion

¶ 23 Juranek asserts that Officer Drake’s testimony discussing

CSPD policies, best practices for foot pursuits, and his compliance

with those policies and practices was improper expert testimony.

¶ 24 We review a trial court’s decision to admit evidence for an

abuse of discretion. See People v. Martinez, 2020 COA 141, ¶ 61.

A court abuses its discretion when its ruling is manifestly arbitrary,

unreasonable, or unfair or when it misapplies the law. Id. But

where, as here, there is no objection at trial, we will reverse the trial

court’s admission of evidence only upon a showing of plain error.

See id. at ¶ 62. An error is plain only if it is both obvious and

substantial. Hagos v. People, 2012 CO 63, ¶ 14.

¶ 25 A witness’s testimony may be classified as lay testimony, lay

opinion testimony, or expert testimony. People v. Murphy, 2021 CO

22, ¶ 17. Lay testimony is based on facts, rather than on opinions,

inferences, or conclusions. Id. Opinion testimony may constitute

lay opinion under CRE 701 or expert opinion under CRE 702,

depending on the basis for the witness’s opinion. Venalonzo v.

People, 2017 CO 9, ¶ 16. If the witness provides testimony that

11
could be expected to be based on an ordinary person’s knowledge or

experiences, then they are offering lay opinion testimony. Id. at

¶ 23. But if the witness provides testimony that could not be

offered without specialized knowledge, experiences, or training, then

they are offering expert testimony. Id.

¶ 26 “Police officers regularly, and appropriately, offer testimony

under CRE 701 based on their perceptions and experiences.”

People v. Tallwhiteman, 124 P.3d 827, 832 (Colo. App. 2005); accord

Murphy, ¶ 21. But an officer’s testimony “becomes objectionable

when what is essentially expert testimony is improperly admitted

under the guise of lay opinions.” People v. Stewart, 55 P.3d 107,

123 (Colo. 2002). However, “simply referencing one’s ‘training and

experience’ does not transform an officer’s lay opinion testimony

into expert testimony.” Murphy, ¶ 31.

¶ 27 We conclude that the challenged testimony was not expert

testimony under the guise of lay opinion testimony because Officer

Drake was not offering an opinion at all. Law enforcement officers

have been permitted to offer lay opinion testimony regarding, for

example, inferences they’ve drawn from the body language of child

witnesses, id. at ¶ 26; whether a razor blade attached to a

12
toothbrush could instill fear of or cause death or bodily injury,

People v. Oliver, 2020 COA 97, ¶ 47; and whether shoeprints found

at a crime scene appeared to match the print of the defendant’s

shoes, Vigil v. People, 2019 CO 105, ¶ 28, because an ordinary

citizen without specialized knowledge or experience would be able to

draw these conclusions. But unlike the testimony in these cases,

Officer Drake wasn’t drawing an inference or conclusion based on

something he perceived. Rather, he was simply describing CSPD’s

policies and explaining his own course of action — that he

terminated the vehicle pursuit quickly because he believed CSPD

policy required him to do so, and that he conducted his foot pursuit

in a particular way based on his understanding of best practices.

See People v. Warrick, 284 P.3d 139, 146 (Colo. App. 2011)

(rejecting the defendant’s argument that a law enforcement officer

gave improper opinion testimony, in part because the testimony

“probably was not an ‘opinion’ in the first instance”).

¶ 28 And even if Officer Drake’s testimony may have veered into

opinion territory at some points, it wasn’t based on specialized

knowledge, experience, or training such that it necessarily

constituted expert testimony. Indeed, a layperson could assess the

13
dangers of car and foot chases, could consider when it might be

reasonable for an officer to continue or discontinue a car chase, and

could contemplate reasonable ways to end a foot chase while

minimizing the risk of harm to the public.

¶ 29 Accordingly, the trial court didn’t err — much less plainly

err — by admitting the challenged testimony.

IV. Prosecutorial Misconduct

¶ 30 Juranek further contends that the trial court erred by allowing

the prosecutor to engage in misconduct during closing argument,

requiring reversal. Again, we disagree.

¶ 31 When we review a claim of prosecutorial misconduct, “we

consider whether the prosecutor’s conduct was improper and

whether any impropriety requires reversal.” People v. Walker, 2022

COA 15, ¶ 27. “Whether a prosecutor’s statements constitute

misconduct is generally a matter left to the trial court’s discretion.”

Domingo-Gomez v. People, 125 P.3d 1043, 1049 (Colo. 2005).

However, if the prosecutor’s statements implicate a defendant’s

constitutional right to remain silent, the court’s decision to allow

the statements is subject to de novo review. People v. Thames,

2019 COA 124, ¶ 25.

14
¶ 32 A prosecutor has wide latitude to make arguments based on

facts in evidence and reasonable inferences drawn from those facts.

People v. Maloy, 2020 COA 71, ¶ 61. Still, a prosecutor’s

arguments must stay within the ethical boundaries drawn by the

courts. Domingo-Gomez, 125 P.3d at 1048.

¶ 33 The parties agree that only one of Juranek’s two prosecutorial

misconduct claims is preserved for appeal. While Juranek’s

preserved claim is governed by the harmless error standard, we

review his unpreserved claim for plain error. See Wend v. People,

235 P.3d 1089, 1097 (Colo. 2010); People v. Licona-Ortega, 2022

COA 27, ¶¶ 87-88. As we’ve indicated, to constitute plain error, an

error must be both obvious and substantial. Hagos, ¶ 14. For

prosecutorial misconduct to constitute plain error, it must be

“flagrantly, glaringly, or tremendously improper,” Domingo-Gomez,

125 P.3d at 1053 (quoting People v. Avila, 944 P.2d 673, 676 (Colo.

App. 1997)), and must “so undermine[] the fundamental fairness of

the trial itself as to cast serious doubt on the reliability of the jury’s

verdict.” Id.

15
A. Reference to Post-Arrest Silence and Decision Not to Testify

¶ 34 Juranek first asserts that the following statements made by

the prosecutor during closing argument improperly referred to his

post-arrest silence and his decision not to testify:

When Officer Drake finally apprehends him
and says, “Hey, you know, don’t take off in a
vehicle, don’t take off running,” he’s not, like,
“What do you mean? What vehicle?” I know
he had a lot of stuff going on, but he’s not
confused. He’s following what Officer Drake
says.

¶ 35 Juranek also points to the following statements the prosecutor

made after replaying the video of him talking to his girlfriend at the

hospital:

He was the driver. He’s not, like, “What are
you talking about? What did they tell you?
That didn’t happen.”

¶ 36 Because Juranek didn’t preserve his challenge to these

statements, our review is for plain error. See People v. Miller, 113

P.3d 743, 748-50 (Colo. 2005) (even constitutional errors are

subject to plain error analysis if they are unpreserved).

¶ 37 We discern no plain error in allowing the statements.

Although it’s generally improper for a prosecutor to comment on a

defendant’s post-arrest silence, if a defendant doesn’t stay silent,

16
it’s not improper to point out omissions in their statements. People

v. Davis, 312 P.3d 193, 198 (Colo. App. 2010), aff’d, 2013 CO 57.

As previous divisions of this court have explained, “[a] defendant

cannot have it both ways” — if the defendant talks, what they say

or omit may be “judged on its merits or demerits.” People v. Knapp,

2020 COA 107, ¶ 51 (quoting Davis, 312 P.3d at 199).

¶ 38 Here, the prosecutor’s arguments related to two portions of the

body camera evidence showing Juranek’s statements after the car

chase and the foot chase.

¶ 39 First, the prosecutor pointed out that, as the body camera

footage shows, when Officer Drake handcuffed Juranek following

the foot chase, the tasing, and Juranek’s fall onto the concrete,

Juranek spontaneously said, “Sorry about that.” Then, when the

officer said, “[T]hat’s why we don’t run from me in a car and then

also on foot,” Juranek responded, “Alright.”

¶ 40 It may well have been fair for the prosecutor to note that

Juranek made those statements — which could be interpreted to

suggest that he understood he had been chased and was apologetic

about it — rather than making any statements indicating that he

had no idea what Officer Drake was talking about. See id.; Davis,

17
312 P.3d at 198. At a minimum, even if the statements went a little

too far into referencing Juranek’s silence, they certainly weren’t so

“flagrantly, glaringly, or tremendously improper” as to constitute

plain error. Domingo-Gomez, 125 P.3d at 1053 (quoting Avila, 944

P.2d at 676).

¶ 41 Also, contrary to Juranek’s suggestion, the prosecutor referred

solely to Juranek’s statements when he was first confronted and did

not in any way allude to his decision not to testify at trial. See

People v. Gallegos, 2023 COA 47, ¶ 92 (the prosecutor’s statements

in closing argument didn’t infringe on the defendant’s right to

remain silent, in part because they neither referred to nor appeared

calculated to direct the jury’s attention to the defendant’s decision

not to testify), aff’d, 2025 CO 41M.

¶ 42 And second, the prosecutor pointed out that when Juranek

called his girlfriend from the hospital and she told him she heard

he’d taken off from the police, he didn’t respond that nothing had

happened or that he had no idea what she was talking about.

Instead, as the body camera footage shows, he insisted that he

“didn’t know they were behind [him],” and that he “pulled over”

thinking they “were after the car in front of [him].” In this context,

18
it was fair for the prosecutor to note the statements Juranek

made — and those he didn’t make. See Knapp, ¶ 51; Davis, 312

P.3d at 198. And as before, the prosecutor didn’t allude in any way

to Juranek’s decision not to testify at trial. See Gallegos, ¶ 92.

¶ 43 Accordingly, we discern no plain error in allowing the

prosecutor’s statements.

B. Conflation of the Charges

¶ 44 Juranek also asserts that the following statements by the

prosecutor improperly conflated the charge for vehicular eluding

with the charge for obstructing a peace officer:

Officer Drake told him, “Fine, get up against
the wall.” He still doesn’t even do that. He
starts walking away again. After not only
leading the officer on a vehicular chase, not
only after running the first time he’s contacted,
but again after the officer finally gets him to
stop and says put your hands behind your
back, he knows what’s going on and he tries to
go away again. All of these actions not only
demonstrate he was the driver, not only
demonstrate he knew he was being pursued,
this is the touchstone of vehicular eluding. So
I’m asking you to find him guilty of that.

The final charge is obstructing a peace officer,
and there is some overlap here between his
knowledge of the eluding and what happened
for the obstruction charge. The obstruction
charge requires that the defendant, on the date

19
and place charged, knowingly, by using or
threatening to use violence, force —

Defense counsel at that point objected, arguing that the prosecutor

was improperly suggesting the jury should consider the car chase

as part of the obstruction charge. The court sustained the objection

and asked the prosecutor “to clarify [that] the car part of things has

nothing to do with the elements of obstructing.”

¶ 45 The prosecutor then continued by listing the elements of

obstruction and outlining the facts supporting those elements, all of

which occurred at the townhome complex.

¶ 46 Even assuming that we can review this claim, notwithstanding

that Juranek didn’t seek any additional relief from the trial court

after it sustained his counsel’s objection, see People v. Douglas,

2012 COA 57, ¶ 65, we discern no error. It’s apparent that the

prosecutor wasn’t trying to conflate the facts relevant to the

vehicular eluding and obstruction charges; instead, she was trying

to argue that because the conduct underlying both charges

occurred close in time and involved fleeing an officer, evidence

supporting one charge could be relevant to establishing Juranek’s

knowledge that he was being pursued and his intent to try to flee as

20
to the other charge. Cf. Rojas v. People, 2022 CO 8, ¶ 26 (other acts

evidence may appropriately be used to establish knowledge and

intent). And while, at first, the prosecutor’s discussion of the facts

was perhaps inartful, the prosecutor did distinctly outline the

elements the prosecution was required to prove as to each charge.

Further, after the court sustained defense counsel’s objection and

requested that the prosecutor clarify the distinction, the prosecutor

stated that the obstruction charge was based on the foot chase that

occurred after Officer Drake arrived at the townhome complex.

¶ 47 Because we discern no error, we decline to disturb the

judgment on this basis.

V. Cumulative Error

¶ 48 Finally, Juranek asserts that cumulative error warrants

reversal.

¶ 49 “The doctrine of cumulative error is based on the notion that

multiple errors, in isolation, may be viewed as harmless, but the

synergistic effect of the multiple errors may be so prejudicial that

they deprive a defendant of a fair trial.” People v. Serna-Lopez, 2023

COA 21, ¶ 47. “Stated simply, cumulative error involves cumulative

prejudice.” Howard-Walker v. People, 2019 CO 69, ¶ 25. Thus,

21
cumulative error analysis is required only when multiple errors

have been identified. Id.

¶ 50 Because we have not identified multiple errors, we reject

Juranek’s cumulative error claim.

VI. Disposition

¶ 51 The judgment is affirmed.

JUDGE PAWAR and JUDGE JOHNSON concur.

22

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
CO Courts
Filed
March 19th, 2026
Instrument
Enforcement
Legal weight
Non-binding
Stage
Final
Change scope
Minor
Document ID
23CA1748
Docket
23CA1748

Who this affects

Applies to
Criminal defendants
Activity scope
Traffic Law Enforcement Criminal Appeals
Geographic scope
Colorado US-CO

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Criminal Justice Traffic Law

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