The Denver-based federal appeals court agreed last week that Colorado satisfied its obligations by not paying a man directly for violating his rights, but rather crediting the jury’s multimillion-dollar award toward the crime victim restitution he still owed in his criminal case.

A three-judge panel of the U.S. Court of Appeals for the 10th Circuit noted that the question was whether Colorado actually paid the jury’s award, “not the lawfulness of procedures facilitating satisfaction.” Despite the intercept, wrote Judge Joel M. Carson III, the legal victory by plaintiff Jason T. Brooks manifested in a reduction to his outstanding restitution balance.

“So we need only consider whether Defendant, in fact, satisfied the judgment,” Carson wrote in a June 23 order. “The benefit of the judgment thus accrued entirely to Plaintiff and his victims (to whom Plaintiff continues to owe an obligation to reimburse).”

Case: Brooks v. Colorado Department of Corrections
Decided: June 23, 2026
Jurisdiction: U.S. District Court for Colorado

Ruling: 3-0
Judges: Joel M. Carson III (author)
Scott M. Matheson Jr.
Allison H. Eid

Brooks was incarcerated after pleading guilty to multiple counts of securities fraud in 2010. Brooks suffered from ulcerative colitis and, while imprisoned, he sought a reasonable accommodation for his disability under the Americans with Disabilities Act. Instead, he wound up missing numerous meals between 2012 and 2018 to deal with his incontinence around mealtimes, in addition to experiencing “stabbing pain” and defecating on himself.

Jurors awarded him $3.5 million in late 2022, and the amount reached nearly $3.66 million with interest.

However, Brooks informed U.S. District Court Judge S. Kato Crews, who presided over his civil trial, that the 19th Judicial District in Weld County subsequently intercepted the payment and applied it to the $5.1 million he owed in crime victim restitution. Brooks then asked Crews to enforce payment of the award to him, arguing the state’s responsibility is not satisfied when it compensates a third party.

In addition to contending that the judicial district’s intercept of the award was not legally authorized, Brooks also argued the government’s actions conflicted with the ADA’s goals of compensating injured plaintiffs and deterring future violations.

The state responded that there was nothing improper about the sequence of events: It paid the amount awarded by the jury, Brooks received an economic benefit in the form of an about 70% reduction in his outstanding restitution debt and his victims were closer to being made whole.

Last year, Crews agreed with the state that Brooks did, in fact, receive the “financial benefit of the payment.”

“Here however, despite not receiving the payment in the form he preferred, it is undisputed that Mr. Brooks received the benefit of the (state’s) payment because the funds were applied to his restitution account from his prior criminal convictions,” wrote Crews.

Representing himself, Brooks maintained on appeal that the state acted unlawfully by seizing his jury award without affording him notice or any other process.

“Under Defendants’ current theory, the Controller may now seize private property on the basis of an internal state request alone, without ever informing the property owner or providing a forum to contest the debt,” he wrote.

“Our holding is not so broad,” Carson wrote in the 10th Circuit panel’s decision. “Instead, we hold that a defendant satisfies a judgment for a plaintiff where that plaintiff owes restitution to crime victims and his judgment is put toward that purpose.”

He added that if Brooks wanted to contest the legality of Colorado’s intercept process, he “must challenge those procedures in a separate action.”

Although the panel originally suggested that federal law applicable to prisoner litigation also authorized the state’s actions, it quickly revised its opinion to remove that reference. The court’s chief deputy clerk told Colorado Politics the issue involved a “clerical error by the Clerk’s Office.”

Brooks has filed a separate lawsuit challenging the legality of the intercept process, which is pending before Crews. He has also asked the 10th Circuit for a rare all-judges’ review of his appeal, arguing that the case implicates federal courts’ ability to ensure defendants fulfill their obligations to successful plaintiffs.

“By declaring this Court powerless to examine whether its own judgment was satisfied — on a record where the plaintiff received nothing, no process was provided … the panel did not merely decide a case,” Brooks wrote. “It created a rule under which any losing party in any federal court may satisfy any civil rights judgment by paying anyone other than the plaintiff, without notice, without hearing, without judicial authorization and without any court possessing jurisdiction to examine what occurred.”

The case is Brooks v. Colorado Department of Corrections.