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

Summary

The court held that a trial court lacked statutory authority to refund costs, fees, or restitution paid after a conviction was vacated when the defendant did not use the statutory exoneration process. The governing fee and restitution statutes and the post-conviction procedural rules did not authorize refunds from public funds, while the Exoneration Act provided the exclusive refund procedure. Justice Hood, dissenting, would have affirmed the refund because Madden had never been validly convicted and should have been restored to his pre-conviction position.