In Re the People of the State of Colorado v. Michael Anthony Manaois

Summary

The court held that the prohibition on consecutive prison-and-probation sentences does not apply when a defendant receives prison for a non-sex offense and consecutive Sex Offender Intensive Supervision Probation for a sex offense. It reasoned that the Sex Offender Lifetime Supervision Act is a freestanding, sex-offense-specific sentencing scheme that reflects legislative approval of that combination and takes precedence over conflicting general sentencing provisions. The court therefore made the rule absolute and remanded for reinstatement of the defendant’s guilty pleas, sentences, and judgment of conviction.