The People of the State of Colorado, Petitioner/cross-Respondent v. Jeffery Allen Loveall, Respondent/cross-Petitioner

Summary

The court held that Loveall's collateral attacks on his guilty plea and deferred judgment were untimely because the statutory requirements he invoked were not jurisdictional, and because a deferred judgment was available for the sex offense. It further held that the late disclosure of hearsay declarants deprived Loveall of the minimum due process required at his probation-revocation hearing, and that the remaining employment violation did not clearly establish that revocation would otherwise have occurred. Justices Eid and Coats concurred in part and dissented in part, agreeing with a new hearing but disputing the majority's treatment of confrontation, hearsay, and disclosure requirements.