People v. Abdul-Rahman.

2026 CO 33. No. 24SC774. Statutory Interpretation—Administrative Exhaustion of Remedies—Parole Revocation Appeals.

May 26, 2026

The supreme court held that a parolee seeking review of the Colorado State Board of Parole’s decision to revoke parole must exhaust administrative remedies before petitioning a court for postconviction relief under Crim. P. 35(c). The court concluded that the statutes governing parole revocation appeals, specifically CRS §§ 17-2-103 and -201, unambiguously require an administrative appeal before seeking judicial review.

Because Abdul-Rahman failed to seek an administrative appeal, the postconviction court lacked jurisdiction to review his Crim. P. 35(c) petition. Accordingly, the court vacated the judgment of the court of appeals and remanded the case with instructions to return it to the postconviction court for dismissal based on lack of jurisdiction.