The Colorado Court of Appeals on March 5, 2026, affirmed the conviction of Ricardo Valdez in People v. Valdez, Weld County District Court Case No. 2019CR1234, for sexual assault and related offenses. The panel held that the evidence was sufficient to show the victim’s submission was obtained through the actual application of physical force, including instances where the defendant moved the victim on a bed to facilitate the assault.
Valdez had challenged the convictions on appeal, arguing the evidence did not establish nonconsent or physical coercion. The appellate court disagreed, emphasizing the trial record supported the jury’s findings, and there were no reversible errors in the lower court’s proceedings.
The ruling underscores that Colorado appellate courts give considerable deference to jury determinations and trial court factfinding in sexual assault cases. For practitioners, it reinforces that movements or actions used to facilitate an assault can constitute sufficient evidence of physical force to support a conviction.