The People of the State of Colorado, Petitioner v. Louis Alonzo Madden, Respondent

Summary

The court held that a trial court lacked authority to refund costs, fees, and restitution paid after a conviction was vacated through post-conviction proceedings. Because the statutes governing those payments and the applicable procedural rules did not authorize refunds from public funds, Madden could seek reimbursement only through the Exoneration Act, which he did not invoke. Justice Hood, dissenting, would have affirmed the court of appeals and allowed Madden to recover the payments because his convictions were ultimately invalidated.