The People of the State of Colorado, Petitioner v. Franck Armand Belibi, Respondent

Summary

The court held that a sentencing court cannot increase a specific restitution amount after entry of the judgment of conviction unless a statutorily authorized order reserved determination of the final amount. Because the sentencing court ordered $4,728 in restitution without reserving authority to determine a later amount, it lacked power to add $302,022 for an insurer's subsequently asserted losses. The court affirmed the court of appeals.