Shaun Jeff Snow v. the People of the State of Colorado

Summary

The court held that Snow received an illegal sentence because the district court deferred restitution in its entirety at sentencing rather than entering one of the restitution orders authorized by statute. Because the sentence was unauthorized by law, Snow's challenge was cognizable at any time under the applicable postconviction rule, and the later restitution order could not cure the defect. The court reversed and remanded for vacatur of the post-sentencing restitution order and entry of an order requiring no restitution.