In Re the People of the State of Colorado v. Patrick S. Keen

Summary

The court held that the general prohibition on combining imprisonment for one offense with probation for another does not bar a prison sentence for a non-sex offense followed by determinate SOISP for a sex-related offense governed by SOLSA. The court relied on SOLSA's legislative history, which showed that the legislature removed sex-related offenses from mandatory indeterminate sentencing to preserve plea-bargaining flexibility while retaining treatment and supervision requirements. The court also found additional support in the crime-of-violence statute and therefore upheld Keen's sentences and remanded for further proceedings.