People v. Coulier

── People v. Coulier ── Court: Colorado Court of Appeals Date: June 04, 2026 Category: General The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion. SUMMARY June 4, 2026 2026 COA 45 No. 24CA1716, People v. Coulier — Crimes — Impersonating a Police Officer In this criminal impersonation of a peace officer case, and as a matter of first impression, a division of the Court of Appeals interprets the phrase “an act” in the statutory element “perform[ed] an act in that pretended capacity.” § 18-8-112(1), C.R.S. 2025. The division holds that “an act” may constitute any conduct that is done while in that pretended capacity and that this interpretation is consistent with federal case law requiring a defendant to engage in conduct that is more than mere bravado, puffery, or bragging. The division further concludes that sufficient evidence of the defendant’s conduct constituting “an act” supported his conviction, and thus, the judgment is affirmed. COLORADO COURT OF APPEALS 2026 COA 45 Court of Appeals No. 24CA1716 El Paso County District Court No. 23CR5191 Honorable Robert L. Lowrey, Judge The People of the State of Colorado, Plaintiff-Appellee, v. Richard James Coulier II, Defendant-Appellant. JUDGMENT AFFIRMED Division III Opinion by JUDGE FREYRE Johnson and Kuhn, JJ., concur Announced June 4, 2026 Philip J. Weiser, Attorney General, Trina K. Kissel, Senior Assistant Attorney General and Assistant Solicitor General, Denver, Colorado, for Plaintiff-Appellee Jeffrey Parsons, Alternate Defense Counsel, Broomfield, Colorado, for Defendant-Appellant ¶1 Defendant, Richard James Coulier II, appeals his conviction for impersonating a peace officer. As a matter of first impression, we are asked to interpret the phrase “an act” in the statutory element “perform[ed] an act in that pretended capacity,” § 18-8- 112(1), C.R.S. 2025, and to decide whether sufficient evidence of Coulier’s conduct constituting “an act” supported his conviction. We conclude that “an act” may constitute any conduct that is done while in that pretended capacity and that this interpretation is consistent with federal case law requiring a defendant to engage in conduct that is more than mere bravado, puffery, or bragging. We further conclude that sufficient evidence supports Coulier’s conviction and affirm the judgment. I. Background ¶2 In November 2023, Coulier and Ann Marie Lopez met at her home to discuss his purchase of an inoperative vehicle that sat in Lopez’s front yard. Coulier said he wished to purchase the vehicle to fix it up for his son. The two agreed that Coulier would pay Lopez $200 for the vehicle and that payment and title would be exchanged once the vehicle became operable. Lopez gave Coulier the keys, and Coulier began making repairs that same day. 1 ¶3 By evening, Coulier was able to start the engine but could not complete all the needed repairs. Without consulting Lopez, Coulier pushed the vehicle from Lopez’s property to his property down the street so he could continue the repairs. When Lopez discovered the vehicle missing the next morning, she called the police and reported it stolen. Coulier continued working on the vehicle until it was operable and then gave the car to his