People v. Thiam - Probation Revocation Appeal
Summary
The Colorado Court of Appeals affirmed the district court's orders revoking Abou Thiam's probation in three separate cases. The revocation was based on new criminal charges, positive drug tests, and failure to comply with counseling and payment requirements.
What changed
The Colorado Court of Appeals affirmed the district court's decision to revoke Abou Thiam's probation in three cases (18CR9162, 19CR4832, and 19CR8433). The revocation was primarily based on Thiam's conviction in a separate case (21CR6328) for attempt to influence a public servant and forgery, which constituted a violation of his probation terms. Additional grounds for revocation included testing positive for cocaine, failing to submit urinalyses, being discharged unsuccessfully from domestic violence counseling, missing appointments, and failing to pay court costs and fines.
This decision means that Thiam's probation remains revoked, and he will likely face the consequences of that revocation, potentially including incarceration, as determined by the district court. The appeal was filed in conjunction with an appeal of his conviction in Case No. 21CR6328. If that conviction were to be reversed, the appellate court indicated it would remand the probation revocation cases for further consideration by the district court.
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March 12, 2026 Get Citation Alerts Download PDF Add Note
Peo v. Thiam
Colorado Court of Appeals
- Citations: None known
- Docket Number: 23CA0961
Precedential Status: Non-Precedential
Combined Opinion
23CA0961 Peo v Thiam 03-12-2026
COLORADO COURT OF APPEALS
Court of Appeals No. 23CA0961
City and County of Denver District Court Nos. 18CR9162, 19CR4832 &
19CR8433
Honorable Ericka F.H. Englert, Judge
The People of the State of Colorado,
Plaintiff-Appellee,
v.
Abou Thiam,
Defendant-Appellant.
ORDERS AFFIRMED
Division IV
Opinion by JUDGE BROWN
Schutz and Berger*, JJ., concur
NOT PUBLISHED PURSUANT TO C.A.R. 35(e)
Announced March 12, 2026
Philip J. Weiser, Attorney General, Patrick A. Withers, Assistant Solicitor
General and Senior Assistant Attorney General, Denver, Colorado, for Plaintiff-
Appellee
Megan A. Ring, Colorado State Public Defender, Daniel J. Sequeira, Deputy
State Public Defender, Denver, Colorado, for Defendant-Appellant
*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art.
VI, § 5(3), and § 24-51-1105, C.R.S. 2025.
¶1 Defendant, Abou Thiam, appeals the district court’s orders
revoking his probation in three cases. We affirm.
I. Analysis
¶2 This case is related to People v. Thiam, (Colo. App. No.
23CA0962, Mar. 12, 2026) (not published pursuant to C.A.R. 35(e))
(Thiam I), which we also announce today.
¶3 In 2019, Thiam pleaded guilty to criminal mischief in Denver
District Court Case No. 18CR9162 and to violation of a protection
order involving domestic violence in Denver District Court Case No.
19CR4832. In 2020, Thiam pleaded guilty to criminal possession of
a financial device in Denver District Court Case No. 19CR8433.
The district court sentenced Thiam to concurrent two-year
probationary sentences in each of these three cases.
¶4 In 2021, while Thiam was on probation, the prosecution
charged him with attempt to influence a public servant and two
counts of forgery in Denver District Court Case No. 21CR6328. As
a result of the new charges, Thiam’s probation officer filed separate
complaints to revoke Thiam’s probation in Case Nos. 18CR9162,
19CR4832, and 19CR8433. The complaints all alleged that Thiam
had violated the terms of his probation because he (1) had been
1
charged with new crimes; (2) tested positive for cocaine; (3) failed to
submit all required urinalyses; (4) was discharged from domestic
violence counseling as unsuccessful; (5) failed to report for
scheduled appointments; and (6) failed to pay court-ordered costs,
fees, and fines.
¶5 In 2023, a jury found Thiam guilty as charged in Case No.
21CR6328. The district court subsequently revoked Thiam’s
probation in Case Nos. 18CR9162, 19CR4832, and 19CR8433
because he had been convicted in Case No. 21CR6328.
¶6 Thiam appealed his conviction in Case No. 21CR6328, Thiam
I, slip op. at ¶ 1. And he separately appealed the revocation of his
probation in Case Nos. 18CR9162, 19CR4832, and 19CR8433 in
this appeal. Here, he argues that if his conviction in Case No.
21CR6328 is reversed, we should reverse the probation revocations
in Case Nos. 18CR9162, 19CR4832, and 19CR8433 and remand
the case for the district court to consider the alternative bases for
revocation alleged in the complaints. Because we affirm the
judgment of conviction in Case No. 21CR6328, Thiam I, slip op. at
¶ 56, we also affirm the court’s orders revoking Thiam’s probation.
2
II. Disposition
¶7 We affirm the district court’s orders.
JUDGE SCHUTZ and JUDGE BERGER concur.
3
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