Nelson v. Colorado

Background

A woman, Shannon Nelson, and a man, Louis Alonzo Madden, were convicted in Colorado and ordered to pay court costs, fees, and restitution. Both later had their convictions overturned or vacated, and Colorado kept money taken from them. Colorado’s Supreme Court said a 2013 Exoneration Act — which lets a person sue and requires proof of actual innocence by clear and convincing evidence — is the exclusive way to seek refunds. Neither petitioner had used that civil claim, so Colorado refused refunds and the cases reached this Court.

Reasoning

The Court addressed a simple, practical question: when a conviction is invalidated and there will be no new trial, must the State return money taken because of that conviction? Applying a three-part balancing test, the Court found the answer yes. It stressed that reversal restores the presumption of innocence, that forcing ex-convicts to pursue a separate civil claim with a heavy proof burden risks keeping money wrongly taken, and that Colorado showed no sufficient government interest in holding the funds. The Court therefore held Colorado’s requirement offends the Fourteenth Amendment’s guarantee of fair process, reversed the Colorado Supreme Court, and sent the cases back for further proceedings consistent with its opinion.

Real world impact

The ruling means people whose convictions are erased and who will not be retried can get back fees, costs, and restitution taken because of those convictions without being forced into the strict Exoneration Act proof scheme. Justice Alito agreed with the result but used a different legal test; Justice Thomas dissented, arguing the Court should first decide whether the money belonged to the defendants under state law before ordering new procedures.