Resentencing Under Allman: Validating Separate Case Sentencing and the Reimposition of Probation

Introduction

The case of Bradford Wayne Snedeker v. The People of the State of Colorado, decided on March 3, 2025, by the Supreme Court of Colorado, presents a significant advancement in the interpretation of the Allman decision. The judgment addresses the legality of sentencing schemes where a defendant initially receives a combined prison-plus-probation sentence in violation of Allman, and the remedial resentencing involves reimposing probation even after a portion of the sentence (imprisonment) has already been served. Moreover, it evaluates whether sentencing a defendant concurrently in separate cases—imposing imprisonment in one and probation in another—conflicts with the Allman principle.

In the present matter, Snedeker had been convicted in two separate district court cases: the Fraud Case and the Theft Case. Following his completion of the prison term in the Fraud Case and while serving probation, Snedeker challenged the continued application of his probationary sentence on the grounds that it violated Allman. The People, on the other hand, sought to enforce revocation proceedings and ultimately secure appropriate sentencing across both cases.

Summary of the Judgment

The Supreme Court of Colorado, in a unanimous decision delivered by Justice Boatright (with Chief Justice Marquez, Justices Hood, Gabriel, Hart, and Samour concurring), addressed two major issues. First, it considered whether a court could reimpose a probation term on a defendant who had already served the prison portion of an unconstitutional prison-plus-probation sentence under Allman. Second, the Court determined if it was permissible to concurrently sentence a defendant to imprisonment in one case while imposing a probation sentence in another separate case.

The Court held that when a sentence is illegal under Allman due to its combined structure, a resentencing that reimposes probation alone (after crediting any time already served in prison) is permissible. Additionally, it concluded that imposing prison in one case concurrently to probation in another does not violate Allman, because the rule in Allman applies to multiple offenses within a single case rather than across distinct cases. Accordingly, the resentencing in both the Fraud Case and the Theft Case was affirmed.

Analysis

Precedents Cited

The Judgment references the seminal decision in Allman v. People, 2019 CO 78, 451 P.3d 826, as the cornerstone of its analysis. In Allman, the Court held that a multi-offense sentencing within one case may not result in a hybrid sentence combining imprisonment for some counts with probation for others. This case served as the imperative framework for assessing the constitutionality of Snedeker’s initial sentencing scheme.

In support of its statutory interpretation and sentencing discretion analysis, the Court also cited cases such as VENSOR v. PEOPLE (regarding the legislature’s exclusive authority to determine punishment) and People v. Jones, Garcia v. People, and People v. Diaz, among others. Each of these decisions reinforced the principles that legislative intent and the plain language of sentencing statutes must guide the Court’s authority in rescinding and correcting illegal sentences.

Legal Reasoning

The Supreme Court’s reasoning is built on two principal considerations. First, it reexamined the statutory basis for imposing probation, citing section 18-1.3-202(1)(a) of the Colorado Revised Statutes, which clearly states that an order for probation takes effect upon entry and does not restrict the court’s discretion in resentencing situations. By noting that a probation-only sentence—especially one that credits previously served prison time—remains within statutory boundaries, the Court upheld the ability to reimpose probation.

Second, the Court distinguished between sentencing decisions made within the confines of a single case versus those rendered across separate cases. While Allman prohibits a hybrid sentence within one case, its rationale was found not to extend to multi-case scenarios. In Snedeker’s situation, the offenses in the Fraud Case were considered independently from those in the Theft Case. Thus, the resentencing that imposed imprisonment in one case and probation in the other did not create the impermissible dual-supervision scenario contemplated by Allman. The Court emphasized the importance of each case’s context, noting that aligning sentencing outcomes strictly across separate cases would severely restrict judicial discretion and lead to disproportionate penalties.

Impact

The decision has substantial implications for future sentencing challenges. By clarifying that courts have the authority to reimpose probation after the imprisonment portion of an illegal sentence has been served, the ruling alleviates concerns that defendants might receive a “windfall” or be unduly punished merely for contesting an unlawful sentence. This differentiation ensures that remedial sentencing adheres to the legislature’s statutory framework while correcting past errors.

Furthermore, the ruling permits sentencing courts to maintain their independent evaluative discretion when handling multiple cases involving the same defendant. This means that courts can tailor sentences based on the distinct facts and severity of each case rather than being forced into a uniform punitive structure across all cases. This flexibility is likely to influence future appellate discussions on sentencing reforms and statutory interpretation, especially in complex instances where legal precedents like Allman might otherwise be viewed as overly restrictive.

Complex Concepts Simplified

One of the central concerns in this Judgment is the “prison-plus-probation” sentencing scheme ruled illegal under Allman. Simply put, Allman prohibits combining a prison term for one count with a probation term for another count when they arise within the same case. The Court reasoned that if a sentence is declared illegal because of this combination, it does not mean that probation becomes an unavailable punishment once the incarceration portion has been served.

Additionally, the issue of concurrent sentencing across different cases was addressed. Though it might seem counterintuitive to impose two separate types of supervision (i.e., imprisonment in one case and probation in another) at the same time, the Court clarified that the legal prohibition in Allman applies only to combined sentencing for related offenses within a single case. When the cases are separate and factually distinct, the statutory schemes governing sentencing allow for different outcomes.

Conclusion

In conclusion, the Supreme Court of Colorado in Bradford Wayne Snedeker v. The People has set a noteworthy precedent in the realm of sentencing law. The decision establishes that:

A court may reimpose a probation term—even after a defendant has served the prison portion of a prior, illegal combined sentence—provided that the resentencing does not bring about a concurrent prison-plus-probation arrangement.
The adjudication of separate cases permits the court to impose divergent sentencing outcomes, such that sentencing imprisonment in one case and probation in another does not violate the principles established by Allman.

This Judgment reinforces the boundaries of the Allman precedent, safeguards judicial discretion in distinct case analysis, and adapts remedial sentencing to both legislative intent and practical exigencies. It underscores that while legislative mandates govern sentencing options, the nuances presented by cases involving multiple convictions require a flexible yet principled approach to legal interpretation.

Ultimately, this decision will serve as an important guiding beacon for lower courts when they confront similar sentencing dilemmas, ensuring that injustice is remedied without unduly constraining the courts’ discretion to impose tailored and appropriate punishments.