Nelson v. Colorado

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Post-Conviction Relief
  • Date Filed: April 19, 2017
  • Case #: No. 15–1256
  • Judge(s)/Court Below: GINSBURG, J., delivered the opinion of the Court, in which ROBERTS, C. J., and KENNEDY, BREYER, SOTOMAYOR, and KAGAN, JJ., joined. ALITO, J., filed an opinion concurring in the judgment. THOMAS, J., filed a dissenting opinion. GORSUCH, J., took no part in the consideration or decision of the cases.
  • Full Text Opinion

Only “minimal procedures” can be placed on persons attempting to recover costs, fees, and restitution that were ordered in criminal convictions for which the persons were subsequently exonerated, as a matter of Due Process.

Petitioners were convicted and ordered to pay costs, fees, and restitution for the crimes. They were subsequently exonerated and filed for post-conviction reimbursement, in the criminal cases, for the amounts paid. The Supreme Court of Colorado reversed the reimbursements pursuant to Colorado’s Compensation for Certain Exonerated Persons statute, Colo. Rev. Stat. §13–65–101 (2016), which required exonerated defendants to prove their innocence by clear and convincing evidence in a civil action before they were reimbursed for fees, costs, and restitution assessed post-conviction. The U. S. Supreme Court disagreed, holding that the three-prong Due Process balancing test set forth in Mathews v. Eldridge, 424 U. S. 319 (1976) controlled. The Court’s analysis provided: (1) “the private interest affected” was met because of Petitioners’ interest in their money, (2) “the risk of erroneous deprivation of that interest through the procedures used” was met because Petitioners were presumed innocent after their exoneration, and the clear and convincing burden created a risk of erroneous results, and (3) the state’s interest in withholding the money was nonexistent. The Court explained that only “minimal procedures” could be enacted without violating the exonerated person's Due Process rights. REVERSED and REMANDED.

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