Zachary Eugene Babcock v. the People of the State of Colorado

Summary

The court affirmed the restitution order, holding that the statutory ninety-one-day deadline for determining restitution is directory rather than jurisdictional and therefore may be waived. It distinguished the court's prior restitution decision because defense counsel requested a hearing nearly six months after sentencing and did not insist on compliance with the deadline. The court further held that counsel's voluntary request for a hearing beyond the deadline impliedly waived the statutory right to a timely determination.