Jeremy Keith Sharrow v. the People of the State of Colorado

Summary

The court held that when an indigent probationer claims that financial inability prevented compliance with a nonpayment condition of probation, the trial court must determine whether the noncompliance was willful or resulted from insufficient bona fide efforts to obtain resources. If the probationer made sufficient efforts, the court must consider alternatives to imprisonment before imposing incarceration, unless no adequate alternative serves the State's sentencing interests. The court affirmed because the record supported the finding that Sharrow had not made sufficient bona fide efforts to obtain employment; Justice Samour delivered the unanimous opinion and no separate writings were recorded.