Do Registered Sex Offenders Lose Internet Rights

Marty East. Whalen Brownish*

[To view a PDF version of this article, click here]

Colorado judges have substantial discretion to make up one's mind the terms of probation for each offender. Trial courts, however, frequently rely on standard terms and conditions for quicker sentencing, and these forms include a full general prohibition against internet access for sex offenders. The Supreme Court recently considered the constitutionality of a ban on social media use by sex offenders in the case Packingham v. Northward Carolina. This Annotate considers whether Colorado's pro­bation practices are constitutional given the Courtroom's holdings in Packingham.

Introduction

Sex offenses come with vastly unlike penalties compared to other crimes.ⁱ Sure categories of punishments are applied broadly across a range of criminal offenses, irrespective of the specific misdeed or manner in which it was committed, and of­10 prohibit internet use and social media access as standard conditions.² Some of the punishments limiting social media ac­cess get so far equally to borrow on the ramble rights of the offender.³

Sexual offenders are some of the most ostracized and shunned members of our club, as shown past the long and harsh history of condemning them through targeted legisla­tion. ⁴ However, what society considers to be an offense—or a sexually deviant or immoral deed—has drastically changed in the final century.⁵ Many changes are generally positive, such every bit protecting the mentally sick, criminalizing marital rape, de­criminalizing sodomy, and prosecuting (more than) allegations of sexual assault and misconduct.⁶ Nevertheless, every bit a consequence of the circuitous legislative history of sexual offenses, many substan­tially bottom crimes are still entangled with the truly heinous and are punished the same only because they qualify as designated sex crimes.⁷ Farther complicating the issue, states and courts vary significantly in how sex offender laws are crafted and interpreted, especially with regard to limiting in­ternet and social media access.⁸In 2017 the Supreme Court unequivocally ruled that North Carolina could not get in a felony offense for a sex offender to use social media afterward completing a court-imposed sentence be­crusade the statutory limitations on oral communication were not sufficiently narrowly tailored.⁹ In this case, Packingham v. Due north Carolina, the Court besides reaffirmed that many sexual offenses are partic­ularly troubling, specially those against children.¹⁰ Such discon­certing sexual offenses must exist weighed heavily when balancing offenders' rights against society's safety and when considering necessary legislative and practical changes.¹¹ Each state, however, forms its own criminal statutory laws. Even though Supreme Court rulings are highly persuasive authority, a ruling against i state does non necessarily require other states to modify their criminal laws if there are differences exist­tween statutory language and awarding.¹² However, Colo­rado should proactively apply the Supreme Court'southward holding in Packingham to Colorado constabulary.

Colorado'south approach to social media employ by convicted sex offenders is substantially different from North Carolina's in terms of codified, duration, and potential penalisation for violations.¹³ This Comment considers the extent to which be­ing exist­ing Colorado police and policies on internet and social media use past sex activity offenders autumn inside the telescopic of the Supreme Court's Packingham ruling. In particular, this Comment focuses on the problems associated with defining social media to differentiate spider web platforms like Facebook from innocuous shopping or news sites.^fourteen Considering Colorado sexual activity offender internet policies are incon­sistent among counties across the state and incongruous in lite of the Packingham conclusion, they should exist updated to ameliorate fit current Supreme Court jurisprudence and to better reflect the ubiquity of technology in mod society.^fifteen

Part I outlines how Colorado's probation sentencing prac­tices currently treat social media apply for sexual practice offenders. Part II examines the Supreme Court's decision in Packingham and its findings regarding constitutionally protected costless speech ex­pressed through social media. Finally, Part 3 proposes changes to improve align Colorado's exercise with the Courtroom's belongings in Packingham.

I. Colorado Probation Police and Policies

Colorado statutes grant the sentencing judge considerable discretion to determine the terms and conditions of probation.¹⁶ Taken together, these statutes provide a sentencing approximate with authority to make up one's mind and modify the conditions of whatever indi­vidual defendant'southward probation term.¹⁷ Additionally, offenders con­victed of sex activity crimes in Colorado are more than restricted on pro­bation than offenders convicted of other crimes, which is especially troubling given that a sexual activity offender may be on proba­tion for 20 years or more.¹⁸ Because of docket pressures and heightened restrictions for sex offenders, courts regularly apply the course Standard Conditions of Probation,¹⁹ Additional Conditions of Probation for Adult Sex Offenders,²⁰ and Com­puter Use Agreement for Sexual activity Offenders²¹ without modification for judicial efficiency when determining the specific conditions of probation. Chiefly, not all of the specific conditions in­cluded in these forms are required past Colorado statute—the conditions that are required in a given case depend on an of­fender'due south specific conviction.²² Moreover, many of the provisions can be modified by judicial whim based on the specific facts of the example, evidence presented at the sentencing hearing, the probation officer'due south presentence report, and any personal opin­ions a guess may have on the thing.²³ Considering trial court judges are often managing an overfull docket, however, the need to move cases through every bit quickly as possible creates strong reliance on standard conditions of probation for sen­tencing.²⁴ The standard weather condition and so allocate substantial dis­cretion to the probation officeholder to decide specific proba­tion terms, including when a probationer has net and social media admission.²⁵

Colorado'southward use of a judicial grade, which lays out the condi­tions used to decide probationary sentencing, allows for the standard conditions to be easily changed and updated equally needed; this would non exist the case if these conditions were codi­fied in statute, as they are in other jurisdictions. Practically speaking, however, these forms are non substantively updated with whatever regularity, and the irresolute step of technology has chop-chop left them glaringly outdated.²⁶ For example, the Com­puter Use Agreement form, last modified in April 2009, refers to the now-obsolete Myspace as the singular example of a social media platform.²⁷ Declining to reflect how society actually uses the internet and technology at a given time diminishes the employ­fulness and effectiveness of the form. An outdated class for in­ternet utilize in a lodge of rapid technological advances and trends does not serve anyone well.

Theoretically, the power of Colorado judges to utilise and modify the standard atmospheric condition of probation would allow for sentences to match the specific crime and criminogenic needs of a particular accused, which in turn would reduce recidivism and ameliorate support offenders' rehabilitation.²⁸ This judicial dis­cretion, however, likewise creates the potential for substantial variation in the terms of probation imposed on offenders with cases that are similar but brought in different Colorado coun­ties or handled by different judges within the aforementioned county.²⁹

The default standard probation terms for sexual practice offenders provide blanket prohibitions on both social media access and more general internet employ, but with the caveat that the super­vising probation officeholder tin allow admission as deemed appropri­ate.^thirty Again, this allows for unrestricted variation in how indi­vidual probationers are treated and ultimately whether they have any social media access at all, regardless of factual dis­similarity between private cases. Because there is no tracking or other statistical data accounting for how probation departments or individual probation officers care for the issue, the percentage of Colorado probationers who are really al­lowed to use social media is unknown. Even more apropos is the fact that the probation officers' determinations of whether to grant social media admission are likely arbitrary and quite pos­sibly inconsistent between cases. Furthermore, in that location is no sta­tistical information available regarding which specific viola­tions prompt probation revocation hearings, making the actual enforcement of such conditions another unknown variable.³¹

Additionally, judges are probable ceding too much of their own ability to probation supervisors. The Colorado General As­sembly grants sentencing judges the authority to determine the terms and atmospheric condition of probation through statute. Specifically "the courtroom may grant the accused probation . . . upon such terms and conditions every bit it deems best,"³² and the "atmospheric condition of probation shall be such as the court in its discretion deems rea­sonably necessary." ³³The courts lack whatsoever statutory authority to further delegate suchpower to the probation department—yet that is precisely what they do.³⁴

In summary, Colorado judges regularly use standard sen­tencing forms to increase judicial efficiency. These forms assign considerable authority to an offender's supervising probation officer to decide when and how internet use and social me­dia admission is advisable, which effectively relinquishes much of the statutorily required judicial oversight to the parole of­ficer. The next Section examines the Packingham determination and its implications for Colorado probationary practices.

II. The Packingham Decision and What Information technology Means for Colorado

Only once has the U.s.a. Supreme Court addressed whether courts may prohibit social media access for convicted sex offenders: in Packingham. ³⁵ In that case, the Court found that a Due north Carolina statute³⁶—which made a registered sex offender'due south use of social media a felony offense—violated the Free Spoken language Clause of the Outset Amendment of the U.s.a. Constitution.³⁷ This Role will first discuss the North Car­olina statute in greater detail, then it volition bear witness how the Packingham doctrine differs from Colorado law and policy, and finally it will identify the troubling trouble of defining "social media."

A. Telescopic of the North Carolina Statute

First and foremost, the Packingham decision affirms that the cyberspace, and notably social media, is a protected forum for complimentary speech.³⁸ Specifically, the Court institute that "one of the nigh important places to substitution views is internet, partic­ularly social media, which offers relatively unlimited low-cost chapters for communication of all kinds to users engaged in a wide array of protected First Amendment activeness on any num­ber of diverse topics."³⁹ The Court has spoken: using social me­dia me­dia is a valid practice of free speech protected past the First Amendment. Free speech, as exercised through social media, may merely be limited to the extent absolutely necessary,⁴⁰ and such limitations should be "narrowly tailored to serve a signifi­cant governmental interest."⁴¹

The Courtroom further emphasized how it had historically sought to protect the fundamental free speech principle of the Kickoff Amendment so "that all persons take access to places where they tin speak and listen" in a spatial context, such as the proverbial street corner.⁴² However, the Court also noted that the modern use of applied science in society extends this pro­tected spatial area to the "vast democratic forums of the Inter­net."⁴³ This is a notable expansion of the traditionally held be­lief that citizens take a right to free spoken language in public spaces, and it may have drastic effects on the regulation of internet utilise and access.⁴⁴ Prior to the Packingham conclusion, various state and federal excursion courts differed significantly on whether it was constitutional for states to prohibit use of social media by an offender.⁴⁵ As a upshot, the country is peppered with wildly divergent holdings on the upshot.⁴⁶

That said, the Court's ruling in Packingham is more than nu­anced than just holding that a complete ban on social media is an unconstitutional violation of the right to gratis speech. Function of the Court's trepidation centers effectually what, exactly, is pro­hibited by the statute and how a violation of such a prohibition should exist punished.⁴⁷ The North Carolina statute at issue spe­cifically stated that it is unlawful for a sex offender to access whatever social networking website where minors are allowed to exist members.⁴⁸ The statute further designated a violation of that prohibition as a new Class I felony offense.⁴⁹ The Supreme Court was particularly concerned past the length of fourth dimension that such a ban would be in place under the statute.^fifty

Of critical importance, this statutory ban on using social media creates a completely separate conditional law-breaking from the original court-imposed sentence that applies only later the original sentence has ended.⁵¹ The Courtroom found it "unsettling to suggest that only a express set of websites can be used even past persons who accept completed their sentences."⁵² Previous rul­ings by the Court do non prove similar concerns over postal service-sen­tence regulations that infringe on constitutionally granted rights, such as prohibiting possession of firearms and voting rights for convicted felons.⁵³ Thus, this concern is either a new legal evolution in how the Court interprets the constitu­tionality of post-judgement regulating statutes or a statement that the constitutionality of such post-sentence regulations are circumstantially dependent on what is being regulated, for whom, and how.⁵⁴

Finally, the Courtroom focused on the bug created by the punishment provisions in the statute, nether which a violation of the statutorily imposed mail service-sentence ban on social media utilise resulted in an additional felony charge confronting the of­fender/‌defendant.⁵⁵ The Court noted in Packingham that the Country never declared that the accused had committed a new criminal offence or illicit act on the internet. The merely crime was violating the statute prohibiting social media use after having a previous sex-offense confidence.⁵⁶ Here, the defendant had posted a sta­tus update on his personal Facebook page regarding the dis­missal of charges from a speeding ticket.⁵⁷ Because the defend­emmet had a previous sex activity-law-breaking conviction, the statute prohibited his using Facebook; consequently his status update became a convictable law-breaking.⁵⁸ The Court establish the combination of what the Northward Carolina statute prohibited, when information technology applied, and the resulting punishment of a new felony confidence to exist "a prohibition unprecedented in the scope of First Subpoena oral communication it burdens."⁵⁹

Other states and judges will undoubtedly endeavor to follow this precedent dutifully,⁶⁰ and Colorado should do the same.⁶¹ Evaluating Colorado constabulary under the Packingham determination is complicated, however, due to the substantive differences in how Colorado's law and policy are applied to the prohibition on and so­cial media utilise for convicted sex offenders. Although not per se unconstitutional, Colorado's statute may still fall within the Packingham rubric and thus may exist unconstitutional—and, as a precaution, Colorado should reform its laws and policies to be able to survive a constitutional challenge under the Packing­ham precedent.

B. Packingham to Colorado

Colorado law, which imposes social media limitations only equally a condition of probation, no longer regulates internet or so­cial media access once the terms of probation are completed.⁶² This is an important difference from the North Carolina stat­ute's application, which continued to run fifty-fifty after the defend­pismire had already served the courtroom-imposed sentence and was no longer incarcerated or nether the courtroom'southward supervision.

Additionally, the penalty for violating the prohibition against social media access differs substantially between Colo­rado and N Carolina. In Colorado, the social media prohibi­tion is simply a condition of probation imposed by the courts, and failing to follow that condition would only exist a violation of pro­bation.⁶³ The legal ramifications under Colorado law are lim­ited to a revocation of probation, which would potentially sub­ject an offender to the original sentence faced in courtroom but, importantly, not to any new criminal charges.⁶⁴ Moreover, this consequence is no different than any other probation viola­tion.⁶⁵ Probation violations and revocation for sexual activity offenders are not distinguished from other classes of offenders, an ironic twist in the criminal justice arrangement so heavily stacked against offenders once convicted.⁶⁶

Colorado's lack of codification and uniform awarding of these conditions makes it difficult to explicitly label such pro­hibitions of social media as fundamentally unconstitutional be­crusade the land does not inflexibly bar access. Regardless of Colorado'due south methodology and whether the Supreme Courtroom could rule it unconstitutional, nonetheless, protecting the ramble rights of an offender while likewise protecting potential victims is still a worthy ambition for the state to pursue. Balancing these protections is a challenge for the legislature.⁶⁷ Even if it may laissez passer the Packingham standard, Colorado still risks unconstitu­tionally burdening complimentary oral communication because of the country'due south inconsist­ence sentencing regime and the legislature'southward imperfect defini­tion of "social media." The next Section volition focus on how courts and legislators struggle to clear how to define social media.

C. Defining Social Media

The Northward Carolina statute reviewed in Packingham de­fined a "commercial social networking Spider web site" broadly.⁶⁸ In dissimilarity, the Colorado statute does not define social networking websites at all. The N Carolina statute stated that a social networking site must: (i) generate revenue, (two) facilitate social interactions between members, (3) allow users to create per­sonal profiles, and (4) provide mechanisms for communication with others.⁶⁹ Justice Alito went to great lengths in the Packing­ham opinion to illustrate how the language in the North Carolina statute encompassed such innocuous websites as Amazon, The Washington Post, and WebMD.⁷⁰ Notably, the Court concluded that the statute'southward overly broad definition in­cluded websites that would be reasonable, appropriate, and even necessary for a sex offender to use. ⁷¹

As a policy concern, the Court also detailed how these ex­traneous websites, though falling nether the broad definition of social media, simply could not facilitate the type of crime the legislature sought to prevent, such every bit straight contacting chil­dren or otherwise identifying potential victims of future crimes.⁷² If the policy goals behind such a prohibition are not being fulfilled, the importance of imposing such a long-lasting prohibition later the completion of a criminal judgement quickly diminishes.⁷³ The Court further acknowledged that convicted criminals "might receive legitimate benefits from these means for access to the world of ideas" and that offenders would po­tentially demand social networking access equally much or fifty-fifty more than than the average citizen.⁷⁴

Ultimately, the Court found that the statute's definition of prohibited social media websites was vastly overreaching.⁷⁵ Namely, "[t]he fatal problem for [the North Carolina statute] is that its wide sweep precludes admission to a large number of web­sites that are most unlikely to facilitate the commission of a sex crime against a kid."⁷⁶ In addition to beingness a violation of the Free Speech Clause, the Courtroom institute that the statute "does not appreciably accelerate the State's goal of protecting children from recidivist sex activity offenders" past placing these websites categorically off limits.⁷⁷

Colorado faces the same problems as N Carolina for creating an advisable definition of social media that volition rea­sonably limit the use of websites like Facebook only not those like WebMD. Listing websites by name is only sufficient until there is a new trending website or some other technological ad­vance that was previously inconceivable.⁷⁸ "The Net's forces and directions are so new, so protean, and then far accomplish­ing that courts must be conscious that what they say today may be obsolete tomorrow."⁷⁹

Thus far Colorado has, intentionally or unintentionally, managed to avoid statutorily defining "social media" for sexual practice of­fenses. Colorado does endeavour to provide a definition of "social networking forum" on the form Additional Weather of Proba­tion for Developed Sexual practice Offenders.^eighty Unfortunately, this definition is broad, is focused on existent-time interactions with others, and also probable includes numerous websites beyond Twitter, Instagram, or Facebook.⁸¹ Once more, the Packingham Courtroom'due south business organisation that broadly prohibiting social media so as to ban near every ma­jor spider web platform will fail to support the purpose behind such prohibitions rings true. Every bit the Court noted, such restrictions on the Free Speech communication Clause must serve a legitimate government in­terest, but also "must not burden substantially more speech communication than is necessary" to achieve this interest.⁸² The authorities'south interest in protecting minors from sex activity offenders is praisewor­thy and potentially sufficient to justify prohibiting their apply of Facebook or Instagram.⁸³ Merely the government has significantly less interest in limiting sex offenders' use of Amazon to pur­chase a bargain-priced Instant Pot.⁸⁴

Ultimately, defining social media is an outcome of scope: how tin can states address the legitimate governmental interests in limiting social media access for sexual practice offenders with a broad enough definition to cover the trending social media platforms of tomorrow, while not including shopping and news outlets? It is of import to remember that the Court did not agree that whatever restriction on social media use would exist categorically imper­missible, but rather that the specific restrictions in the North Carolina statute were problematic.⁸⁵ Indeed, the Court af­firmed that "the First Amendment permits a State to enact specific, narrowly tailored laws that prohibit a sex offender from engaging in conduct that often presages a sexual criminal offense, like contacting a pocket-sized or using a website to gather infor­mation about a small-scale."⁸⁶ Thus, it is critically important to care­fully consider the precise language and awarding of the North Carolina statute as well as how other states and circuits are addressing these widespread issues.

The key distinctions between the Colorado and North Automobile­olina laws are: (1) the lack of codification of the social media prohibition, (2) the time when the prohibition against social media use applies, and (3) the punishment being a probation revocation. Colorado faces the aforementioned claiming as Due north Caro­lina, even so, in defining social media to categorically include intended websites like Facebook and categorically exclude the innocuous ones like Amazon. Colorado should strive to update its existing laws and practices to better address the concerns raised by the Court in Packingham and protect citizens' First Amendment rights.

Three. Changes to Consider for Colorado Law

The Courtroom's property in Packingham triggers a responsibil­ity for states to critically appraise their ain limitations on so­cial media utilize for sex offenders. This Role first argues that Colorado should reevaluate its public policy concerns underly­ing these procedures, so proposes modifications for the state to consider. Colorado would be well served if it modified the "sex offender" designation to ameliorate reflect different levels of offenses and applied standardized probation terms deter­mining social media access for each level.

A. Public Policy Concerns

Colorado should consider whether limitations on social media actually serve public policy goals and, if not, make changes accordingly. People strongly dislike sex-offender crimes, particularly when committed towards children, and want to feel that their communities are beingness protected from reoffending perpetrators.⁸⁷ Thus it is easy to come across how broad laws prohibiting use of the cyberspace and social media—espe­cially laws that target websites where minors can have ac­counts—are seen as necessary to adequately protect the com­munity. In improver to including innocuous websites, however, this expansive approach also encompasses an overly wide swath of offenders.

Without a doubt, sex offenders have relied upon social me­dia to commit abhorrent crimes against children and other vul­nerable individuals, and access to these internet platforms should be severely express for such offenders.⁸⁸ Many other sex offenders, withal, have committed much less serious crimes with piffling or no reliance on the internet.⁸⁹ As a guild, the demand to protect the population from genuinely heinous acts must also be balanced with the rights and personal integrity of the offender.⁹⁰

Sex offenders vary in the execution of their crimes, using different methods to interact with the victim and commit the bodily crime,⁹¹ which presents additional challenges for effec­tively reducing recidivism with social media bans. How an in­dividual offender used social media in the original criminal offence, or how he would be likely to use social media in a future offense, is highly offender dependent, which is distinct from social media use beingness criminal offense dependent. To clarify, the likelihood of an of­fender using social media to commit a future human action is a divide consideration from whether the original crime was committed through social media.⁹² Some methods of victim pick⁹³ lend themselves much more to using social media than others, and the propensity for recidivism is significantly influenced by non-criminal offense-specific factors such every bit the offender'due south home environment and community back up.⁹⁴

Arrests for sex activity crimes over the by two decades take steadily decreased even equally changes in applied science have made it easier and easier for sex offenders to identify and access vic­tims online.⁹⁵ All the same while arrests have declined, "public concern has risen."⁹⁶ Appropriately addressing such concerns is undenia­bly important, but the judicial co-operative may exist severely handicapped in making bodily changes if public business organisation is not grounded in reality. Farther public teaching may be needed to change the societal narrative about such crimes. Equally discussed higher up, Colorado'due south statutorily stated purpose with respect to sentencing is all-encompassing but, importantly, includes both "to punish" and "to promote rehabilitation." ⁹⁷ These simultane­ous goals are critical when considering what changes should be made to Colorado law.

B. Implementations for Colorado

Colorado should revise how sexual activity offenses are designated to better differentiate between the wide array of crimes that are currently included under the broad "sex offender" label. Having different levels of sex offenses would allow offenders who practice not commit crimes against children or crimes that are not other­wise particularly egregious—offenses that are not predatory or have a low likelihood of reoffending—to all the same have a Facebook business relationship. Once unlike categories of sex offenses are estab­lished, corresponding appropriate standard conditions of proba­tion could be instituted for each. Limitations on cyberspace and social media use could exist direct correlated to the specific blazon of crime committed and the criminal methodology used past the specific offender, which would ultimately allow low-risk offend­ers to keep their net access equally the default condition. Be­cause Colorado already distinguishes different crimes and sen­tencing guidelines, fine-tuning the sex activity offender category should be a feasible next stride.

Sorting sex offenses into specific categories would as well lead to more uniformity between judges and across county lines for similarly situated sexual practice offenders. The Legislature has desig­nated categories of crimes past land-wide statute, and the judi­ciary should strive to apply punishments for each category equally consistently and predictably as possible. Finally, creating levels of sex offender crimes, and subsequent conditions of probation based upon those levels, reduces some of the unbridled discre­tion currently vested in probation supervisors and returns it to judges, while keeping probation sentencing efficient to back up the time-strapped judges.

Conclusion

Colorado courts accept substantial discretion to determine the terms and weather condition of probation for each offender.⁹⁸ How­always, the courts often rely on the form Atmospheric condition of Probation and Boosted Conditions of Probation for Adult Sex activity Offend­ers, deferring to the probation officer to determine a item offender's social media and internet admission.⁹⁹ This lack of codifi­cation of the terms of probation and the fact that such terms only apply during supervisory probation distinguishes Colorado policy from the North Carolina statute at issue in Packing­ham. ¹⁰⁰ That said, the existing Colorado methods practise non serve public policy concerns peculiarly well because of the vast range of offenses that qualify every bit "sex offender" crimes and the discrepancies among imposed sentences.¹⁰¹ The current Colo­rado arrangement besides does non seem to follow the spirit of the Pack­ingham decision and similarly struggles to define "social me­dia" every bit North Carolina.¹⁰² The citizens of Colorado would be better served if the legislature separated different sexual practice offenses into split up categories based on criminal offence methodology and vic­tim, where each category has a different default standard for whether social media utilise is allowed. Such categorization of sexual activity offenses would also help judges and probation offices across the land follow more consistent sentencing practices, with better, more narrowly tailored definitions for prohibited websites.

Appendix

---

*Juris Md, 2019, University of Colorado Constabulary School; Casenote & Comment Editor, University of Colorado Law Review, Book 90. I want to recognize and thank my editors Erica Lieber, Jonathan McGuire, and Hannah Armentrout for all the support and assist they provided me throughout this procedure. I would also like to thank Professor Amy Griffin for her invaluable guidance and encouragement. Finally, I want to thank my hubby, Wes, for believing in me throughout law school and especially for cooking me dinner every night. And to my daughters, Kristina and Adrianna, I'g sorry for how many weekends I spent ignoring you to piece of work on this piece; I love y'all both.

Do Registered Sex Offenders Lose Internet Rights,

Source: https://lawreview-dev.cu.law/banning-facebook-sex-offenders-probation-and-social-media-under-colorado-law/

Posted by: portertherose.blogspot.com

Share this post