Supreme Court of Colorado

The People of the State of Colorado v. Robert Sandoval-Candelaria

March 24, 2014321 P.3d 487

Summary

The court held that a six-month-and-seven-day delay in sentencing was not unreasonable under Crim. P. 32(b) because it allowed the trial court to determine whether the defendant's separate felony conviction triggered an aggravated sentencing range. The court also held that the delay was not presumptively prejudicial for purposes of the defendant's claimed constitutional right to speedy sentencing, so no further balancing was required. The court reversed the court of appeals and directed reinstatement of the twelve-year sentence.