People v. Sheth, 2013 COA 33

In 2008, Sheth pled guilty to Class 5 felony attempted Internet sexual exploitation of a child; probation for 36 months with sex offender treatment and no contact with minors; registration as a sex offender required under the Act.
In 2011, district court reduced his probation to two years, and probation ended by operation of law.
Sheth filed a CRCP 57 declaratory judgment seeking to terminate his registration duties upon probation termination.
The district court held the ten-year waiting period before termination applies under § 16-22-113(1)(b), with no exception to allow earlier termination.
The court concluded registration duties are not punitive but are protective information; failure to register is a felony, and termination requires ten years after final release.
The Colorado Court of Appeals affirmed, holding the ten-year wait is unambiguous and controlling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §16-22-113(1)(b) requires a ten-year wait before termination.	Sheth contends probation termination ends duties.	State argues ten-year wait after final release is mandatory.	Ten-year wait required; no exception permitting earlier termination.
Whether registration duties terminate with probation if not compelled by statute.	Probation conditions terminate with probation.	Statutory duty to register persists beyond probation; termination only per statute.	Registration duties survive probation and require statutory termination procedure.

People v. Carbajal, 2012 COA 107 (Colo. App. 2012) (registration not punishment; purpose is public safety)
Mayo v. People, 181 P.3d 1207 (Colo. App. 2008) (registration provisions are informational, not punitive)
Dubois v. Abrahamson, 214 P.3d 586 (Colo. App. 2009) (registration information aids enforcement, not retribution)
People v. Perry, 252 P.3d 45 (Colo. App. 2010) (statutory interpretation governs labeling of provisions)
Bostelman v. People, 162 P.3d 686 (Colo. 2007) (principles of statutory interpretation and harmonization)