Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-06-23

Docket: 1:13-CV-02894-SKC)

The Tenth Circuit affirmed the district court’s denial of a prisoner’s motion for a writ of execution and its dismissal of related claims, holding that the Colorado Department of Corrections satisfied the $3.5 million judgment entered under the Americans with Disabilities Act (ADA) when state authorities redirected the funds to pay the plaintiff’s outstanding restitution debts to crime victims. The court applied the standard of de novo review to the legal question of whether a judgment is satisfied and relied on the principle that federal courts possess only “ancillary jurisdiction” over post-judgment proceedings necessary to enforce their own judgments, which terminates once the judgment is satisfied. Distinguishing prior circuit cases involving recoupment schemes that frustrated federal rights enforcement, the court reasoned that diverting funds to satisfy a prisoner’s restitution obligations provides the plaintiff with the financial benefit of the judgment and does not defeat the compensatory or deterrent purposes of the ADA. Consequently, because the judgment was deemed satisfied, the district court lacked subject-matter jurisdiction to review the lawfulness of Colorado’s intercept statute or to entertain new claims against non-parties regarding the diversion procedures. The practical consequence is that the plaintiff’s appeal is dismissed as moot, and he must pursue any challenges to the state’s interception procedures in a separate action rather than through enforcement of the original federal judgment.

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