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People v. Rediger

Colo.April 30, 2018No. Supreme Court Case 15SC326Cited 1929 times
Mixed Resultnonprofit school

Case Details

Status
Published
Procedural Posture
Appeal to Colorado Supreme Court; affirmed in part and reversed in part

Related Laws

No specific laws identified for this ruling.

Outcome

Colorado Supreme Court reversed conviction for interference with public employee, finding nonprofit school owner-director is not a public employee. Court also found plain error in jury instructions constituting constructive amendment of charging document, requiring new trial.

Excerpt

This case required the Supreme Court to decide two questions: (1) whether the owner–director of a nonprofit school regulated by various governmental entities is a "public employee" within the meaning of CRS § 18-9-110(1), and (2) whether respondent waived or invited error with respect to a constructive amendment claim when his defense counsel stated that he was "satisfied" with the proposed jury instructions, notwithstanding the fact that the elemental instruction on the charge of interference with the staff, faculty, or students of an educational institution tracked CRS § 18-9-109(1)(b) rather than CRS § 18-9-109(2), which was the subsection charged in the information. As to the first question, the Court concluded that "public employee" means an employee of a governmental entity, and therefore an employee of a nonprofit school is not a public employee. Accordingly, the Court agreed with the Court of Appeals division's decision that respondent's conviction for interference with a public employee in a public building cannot stand. As to the second question, the Court concluded that respondent neither waived nor invited error with respect to his constructive amendment claim because the record does not indicate that he or his counsel either intentionally relinquished a known right or deliberately injected the erroneous jury instruction as a matter of trial strategy. The Court instead construed respondent's general acquiescence to the instructions as a forfeiture and, reviewing for plain error, concluded that the constructive amendment of respondent's charging document constituted plain error necessitating a new trial. The Court affirmed in part and reversed in part the Court of Appeals division's judgment.

What This Ruling Means

**What Happened** A person named Rediger was charged with interfering with a public employee at a nonprofit school where he served as owner-director. The case centered on whether someone who owns and runs a private nonprofit school that receives government regulation should be considered a "public employee" under Colorado law. Rediger was convicted at trial, but he appealed the decision. **What the Court Decided** The Colorado Supreme Court overturned Rediger's conviction. The court ruled that being the owner-director of a nonprofit school does not make someone a "public employee," even if the school is regulated by government agencies. The court also found serious errors in the jury instructions that were so significant they required a completely new trial. **Why This Matters for Workers** This ruling clarifies an important distinction between public and private employees. Just because a private organization receives government funding or oversight doesn't automatically make its workers "public employees." This affects what legal protections apply and what charges can be brought in workplace disputes. The decision helps define the boundary between public and private employment, which can impact workers' rights, benefits, and the laws that govern their workplace relationships.

This summary was generated to explain the ruling in plain English and is not legal advice.

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