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13 Colorado opinions name it 2 courts 2012–2026 9 in the last five years
The cases below were cited by Colorado courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
The People of the State of Colorado v. Benjamin Weeksgreen2 sentences2024Pursuant to the statute, every order of conviction must include one of four types of restitution orders: (a) an order to pay a specific amount; (b) an order obligating the defendant to pay restitution but deferring t he establishment of the actual amount owed; (c) an order that the defendant is obligated to pay the actual costs of specif ic future treatment for the victim; or (d) a finding that no victim suffered a 2 pecuniary loss and thus no restitution is owed . § 18 -1.3-603(1)(a)- (d) ; Weeks , ¶ 3. ¶ 3 In Weeks , t he supreme court held that the ninety-one-day deadline for determining re 2024Pursuant to the statute, every order of conviction must include one of four types of restitution orders: (a) an order to pay a specific amount; (b) an order obligating the defendant to pay restitution but deferring t he establishment of the actual amount owed; (c) an order that the defendant is obligated to pay the actual costs of specif ic future treatment for the victim; or (d) a finding that no victim suffered a 2 pecuniary loss and thus no restitution is owed . § 18 -1.3-603(1)(a)- (d) ; Weeks , ¶ 3. ¶ 3 In Weeks , t he supreme court held that the ninety-one-day deadline for determining re | 2 | 2 |
People v. Harmangreen2 sentences2020People v. Harman, 97 P.3d 290, 294 (Colo. App. 2004). 2020See People v. McCann, 122 P.3d 1085, 1088 (Colo. App. 2005); People v. Harman, 97 P.3d 290, 294 (Colo. App. 2004). | 2 | 2 |
Sanoff v. Peoplegreen1 sentence2025See Sanoff, 187 P.3d at 578 . | 1 | 1 |
The People of the State of Colorado v. Zachary Eugene Babcockgreen1 sentence2024People v. Babcock, 2023 COA 49, ¶¶ 1, 5-11 . ¶ 18 We find People v. Johnson, 2023 COA 43M , instructive concerning waiver. | 1 | 1 |
People v. Belibigreen2 sentences2020See People v. Belibi, 2018 CO 24, ¶ 7 , 415 P.3d 301, 302 (explaining that section 18-1.3-603(1)(b) requires that “the specific amount of restitution be set within ninety-one days”) (emphasis added); Meza v. People, 2018 CO 23, ¶ 14 , 415 P.3d 303, 308 (holding that section 18-1.3-603(1)(b) allows a district court to “reserv[e] until a later date, within ninety-one days, findings with regard to other victims or losses of which the prosecution is not yet aware”) (emphasis added); Perez, ¶¶ 14-15, ___ P.3d at ___ (“If the court reserves the determination of restitution, as it is authorized to do 2020See People v. Belibi, 2018 CO 24, ¶ 7 , 415 P.3d 301, 302 (explaining that section 18-1.3-603(1)(b) requires that “the specific amount of restitution be set within ninety-one days”) (emphasis added); Meza v. People, 2018 CO 23, ¶ 14 , 415 P.3d 303, 308 (holding that section 18-1.3-603(1)(b) allows a district court to “reserv[e] until a later date, within ninety-one days, findings with regard to other victims or losses of which the prosecution is not yet aware”) (emphasis added); Perez, ¶¶ 14-15, ___ P.3d at ___ (“If the court reserves the determination of restitution, as it is authorized to do | 1 | 1 |
Meza v. Peoplegreen2 sentences2020See People v. Belibi, 2018 CO 24, ¶ 7 , 415 P.3d 301, 302 (explaining that section 18-1.3-603(1)(b) requires that “the specific amount of restitution be set within ninety-one days”) (emphasis added); Meza v. People, 2018 CO 23, ¶ 14 , 415 P.3d 303, 308 (holding that section 18-1.3-603(1)(b) allows a district court to “reserv[e] until a later date, within ninety-one days, findings with regard to other victims or losses of which the prosecution is not yet aware”) (emphasis added); Perez, ¶¶ 14-15, ___ P.3d at ___ (“If the court reserves the determination of restitution, as it is authorized to do 2020See People v. Belibi, 2018 CO 24, ¶ 7 , 415 P.3d 301, 302 (explaining that section 18-1.3-603(1)(b) requires that “the specific amount of restitution be set within ninety-one days”) (emphasis added); Meza v. People, 2018 CO 23, ¶ 14 , 415 P.3d 303, 308 (holding that section 18-1.3-603(1)(b) allows a district court to “reserv[e] until a later date, within ninety-one days, findings with regard to other victims or losses of which the prosecution is not yet aware”) (emphasis added); Perez, ¶¶ 14-15, ___ P.3d at ___ (“If the court reserves the determination of restitution, as it is authorized to do | 1 | 1 |
People v. McCanngreen1 sentence2020See People v. McCann, 122 P.3d 1085, 1088 (Colo. App. 2005); People v. Harman, 97 P.3d 290, 294 (Colo. App. 2004). | 1 | 1 |
People v. Rocknegreen1 sentence2016Rockne , ¶ 21 (stating that where the “final amount of restitution” has been ordered, the prosecution is barred from obtaining a supplemental restitution order under section 18-1.3-603(3)). | 1 | 1 |
People v. Wallingreen1 sentence2012See People v. Salazar, 964 P.2d 502, 507 (Colo.1998) ("It is axiomatic that issues not raised in or decided by a lower court will not be addressed for the first time on appeal."); People v. Wallin, 167 P.3d 183, 187 (Colo.App.2007) (declining to address arguments presented in a perfunctory or conclusory manner). . - An initial order of restitution under section 18-1.3-603(i) and (2) would deny restitution; set forth a specific amount of restitution; or recognize a defendant's responsibility for paying, in lieu of or in addition to a specific amount of money, ""the actual costs of specific futu | 1 | 1 |
People v. Salazargreen1 sentence2012See People v. Salazar, 964 P.2d 502, 507 (Colo.1998) ("It is axiomatic that issues not raised in or decided by a lower court will not be addressed for the first time on appeal."); People v. Wallin, 167 P.3d 183, 187 (Colo.App.2007) (declining to address arguments presented in a perfunctory or conclusory manner). . - An initial order of restitution under section 18-1.3-603(i) and (2) would deny restitution; set forth a specific amount of restitution; or recognize a defendant's responsibility for paying, in lieu of or in addition to a specific amount of money, ""the actual costs of specific futu | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Colorado. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Shaun Jeff Snow v. The People of the State of Colorado
green
2 sentences2026Cf. Snow v. People, 2025 CO 32 , ¶¶ 2, 7-8, 23, 29 (concluding that the district court failed to order restitution under any subsection of section 18-1.3-603(1) and that the issue of restitution was illegally reserved in its entirety when “the district court proceedings [were] barren of an explicit or implicit finding of restitution liability”). ¶ 39 Second, the district court retained authority to enter a restitution order seventy-two days after sentencing even though it failed to enforce the prosecution’s obligations under section 18-1.3-603(2)(a). 2026As a result, the automatic vacatur rule discussed in Snow v. People, 2025 CO 32 , ¶¶ 30-40, is not implicated. 5 1.3-603(2)(a)] controls is the timeframe within which the prosecution must submit the proposed amount of restitution.”). ¶ 14 We recognize that the prosecutor did not specify at the sentencing hearing that the requested amount would be split between H.T. and A.T. | 2 | 2026–2026 |
Audrey Lee Tennyson v. The People of the State of Colorado
green
2 sentences2026See § 18-1.3- 603(1)(b) (authorizing “[a]n order that the defendant is obligated to pay restitution, but that the specific amount of restitution shall be determined” later); cf. Tennyson v. People, 2025 CO 31 , ¶¶ 10, 45 (concluding that the trial court implicitly found at sentencing that the defendant was liable for restitution but that the amount of restitution would be determined later); People v. Tennyson, 2023 COA 2 , ¶ 37 (clarifying that the mittimus in Tennyson did not include any notation regarding restitution), aff’d, 2025 CO 31 ; see also Weeks II, ¶ 7 n.4 (“In requiring an express 2026See § 18-1.3- 603(1)(b) (authorizing “[a]n order that the defendant is obligated to pay restitution, but that the specific amount of restitution shall be determined” later); cf. Tennyson v. People, 2025 CO 31 , ¶¶ 10, 45 (concluding that the trial court implicitly found at sentencing that the defendant was liable for restitution but that the amount of restitution would be determined later); People v. Tennyson, 2023 COA 2 , ¶ 37 (clarifying that the mittimus in Tennyson did not include any notation regarding restitution), aff’d, 2025 CO 31 ; see also Weeks II, ¶ 7 n.4 (“In requiring an express | 1 | 2026–2026 |
The People of the State of Colorado v. Jessica Jo Roberson
green
1 sentence2026Remedy for an Illegal Sentence ¶ 22 When the district court fails to enter one of the four enumerated restitution orders in section 18-1.3-603(1)(b) at sentencing and later enters a post-sentencing restitution order, “the 2 The People also cite Johnson v. People, 2025 CO 29 , and People v. Roberson, 2025 CO 30 , for the proposition that a restitution order may be inferred from a plea agreement. | 1 | 2026–2026 |
Darryl Cornelious Johnson, Petitioner/Cross-Respondent v. The People of the State of Colorado. Respondent/Cross-Petitioner
green
1 sentence2026Remedy for an Illegal Sentence ¶ 22 When the district court fails to enter one of the four enumerated restitution orders in section 18-1.3-603(1)(b) at sentencing and later enters a post-sentencing restitution order, “the 2 The People also cite Johnson v. People, 2025 CO 29 , and People v. Roberson, 2025 CO 30 , for the proposition that a restitution order may be inferred from a plea agreement. | 1 | 2026–2026 |
v. Weeks
green
2 sentences2021The division continued that, "if the prosecution needs the full ninety-one days (or more) to complete its request for restitution under section 18-1.3-603 (2) , that in itself could constitute 'good cause' for the trial court to extend its restitution ruling beyond the ninety-one-day deadline under section 18-1.3-603 (1) (b) ." Id. at ¶ 20 , 490 P.3d at 676 . ¶20 Because the trial court neither determined the restitution amount within ninety-one days of the judgment of conviction nor found good cause to extend that deadline, the division held that the trial court lacked authority to enter the 2021The division continued that, "if the prosecution needs the full ninety-one days (or more) to complete its request for restitution under section 18-1.3-603 (2) , that in itself could constitute 'good cause' for the trial court to extend its restitution ruling beyond the ninety-one-day deadline under section 18-1.3-603 (1) (b) ." Id. at ¶ 20 , 490 P.3d at 676 . ¶20 Because the trial court neither determined the restitution amount within ninety-one days of the judgment of conviction nor found good cause to extend that deadline, the division held that the trial court lacked authority to enter the | 1 | 2021–2021 |
Cowen v. People
green
2 sentences2020Our answer is that if the prosecution needs the full ninety-one days (or more) to complete its request for restitution under section 18-1.3-603(2), that in itself could constitute “good cause” for the trial court to extend its restitution ruling beyond the ninety-one-day deadline under section 18-1.3-603(1)(b). ¶ 21 But a district court’s finding of good cause must rest on the specific facts of the case and not merely on the General Assembly’s decision to set the same deadline for a district court’s determination of the amount of restitution and the prosecuting attorney’s presentation of the i 2020Our answer is that if the prosecution needs the full ninety-one days (or more) to complete its request for restitution under section 18-1.3-603(2), that in itself could constitute “good cause” for the trial court to extend its restitution ruling beyond the ninety-one-day deadline under section 18-1.3-603(1)(b). ¶ 21 But a district court’s finding of good cause must rest on the specific facts of the case and not merely on the General Assembly’s decision to set the same deadline for a district court’s determination of the amount of restitution and the prosecuting attorney’s presentation of the i | 1 | 2020–2020 |
People v. Turecek
green
2 sentences2012In reaching this conclusion, we necessarily reject, as misplaced, defendant's reliance on People v. Turecek, 2012 COA 59 , 280 P.3d 73 . 2012In reaching this conclusion, we necessarily reject, as misplaced, defendant's reliance on People v. Turecek, 2012 COA 59 , 280 P.3d 73 . | 1 | 2012–2012 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.