Background
A jury convicted Laurence Rene Goodman of several non-class 1 felonies, including a Colorado Organized Crime Control Act violation. The trial court sentenced him on March 20, 2019, to an aggregate 30-year Department of Corrections term. Goodman did not properly pursue a direct appeal.
In 2020, Goodman filed a pro se Crim. P. 35(c) motion alleging constitutional and jurisdictional defects; the district court denied it, and he did not appeal. About five years later, he filed another Rule 35(c) motion alleging impaired self-representation, trial-preparation barriers, a grossly disproportionate sentence, and alleged effects from the now-overruled Chevron doctrine.
The Court’s Holding
The Colorado Court of Appeals affirmed the denial of postconviction relief because Goodman’s May 2025 motion was untimely. For a non-class 1 felony, Rule 35(c) claims must be filed within three years after the conviction becomes final. Because Goodman did not perfect a direct appeal, his conviction became final at sentencing on March 20, 2019, making the filing deadline March 20, 2022.
Goodman did not adequately allege a statutory exception based on justifiable excuse or excusable neglect. His reference to Loper Bright Enterprises v. Raimondo and a purported material change in law did not explain why that decision supplied a new substantive constitutional rule retroactively applicable on collateral review. The court also declined to consider claims newly raised or expanded on appeal.
Key Takeaways
- Colorado defendants generally have three years after a non-class 1 felony conviction becomes final to bring Rule 35(c) claims.
- A conclusory assertion that a decision changed the law does not establish justifiable excuse or excusable neglect for a late filing.
- An appellate brief cannot add new postconviction claims or cure claims inadequately presented to the district court.
Why It Matters
The decision reinforces that Colorado’s postconviction deadline applies even to constitutional and sentencing challenges unless the movant specifically pleads facts establishing a statutory exception. Litigants relying on intervening precedent must explain its relevance and retroactive applicability, rather than merely cite it as a legal development.