Supreme Court of Colorado
The People of the State of Colorado v. Spencer Klinton Smith
February 3, 2014318 P.3d 472
Summary
The court held that the felony presentence-confinement-credit statute does not apply when an offender receives probation with a jail component. Accordingly, the trial court had discretion to award all, part, or none of the presentence confinement credit against that jail term, and the court reversed the court of appeals. The court also rejected Smith's equal-protection argument because offenders remain subject to the same statutory sentencing ranges and probation is an alternative sentence that may be accepted or rejected.