Carlos Meza, Petitioner v. the People of the State of Colorado, Respondent

Summary

The court held that the county court lacked authority to increase a specifically ordered restitution amount after entry of the judgment of conviction because no statutorily authorized reservation of the final amount had been made. The notation "RR" on the plea form did not reserve restitution for later determination, and the statutory ninety-one-day period did not independently preserve the court's power to increase a specific restitution order. The court reversed and remanded with directions to reinstate the $150 restitution order.