Shannon Nelson, Petitioner v. Colorado. Louis A. Madden, Petitioner v. Colorado.

Summary

The Court held that when a criminal conviction is invalidated and no retrial will occur, the State must refund fees, costs, and restitution exacted on that conviction. Colorado's Exoneration Act, which requires defendants to prove innocence by clear and convincing evidence to obtain refunds, violates the Fourteenth Amendment's Due Process Clause because it fails to account for the presumption of innocence restored upon reversal. Justice Thomas dissented, arguing petitioners lacked a substantive property interest under state law.