The People of the State of Colorado v. Jessica Jo Roberson

2025 CO 30
CourtSupreme Court of Colorado
DecidedMay 27, 2025
Docket23SC622
StatusPublished

This text of 2025 CO 30 (The People of the State of Colorado v. Jessica Jo Roberson) is published on Counsel Stack Legal Research, covering Supreme Court of Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The People of the State of Colorado v. Jessica Jo Roberson, 2025 CO 30 (Colo. 2025).

Opinion

Certiorari to the Colorado Court of Appeals Court of Appeals Case No. 21CA1713

Judgment Reversed

Attorneys for Petitioner: Philip J. Weiser, Attorney General Brittany Limes Zehner, Assistant Solicitor General Denver, Colorado

Attorneys for Respondent: Megan A. Ring, Public Defender James S. Hardy, Lead Deputy Public Defender Denver, Colorado

Attorneys for Amicus Curiae Rocky Mountain Victim Law Center: Matthew Beresky Justin Summers Lakewood, Colorado

Justice Hart delivered the Opinion of the Court, in which Justice Boatright, Justice Hood, Justice Samour, and Justice Berkenkotter joined. Justice Gabriel, joined by Chief Justice Márquez, concurred in the judgment.

OPINION

HART, JUSTICE

¶1 Jessica Jo Roberson pleaded guilty to one count of forgery and one count of theft and agreed to pay $21,450 in restitution, with "additional restitution" to be determined. Defense counsel confirmed this agreement to the court during the providency hearing. Then at sentencing, Roberson herself told the court that she "most definitely want[ed] to repay the victims." Twenty-eight days later, the prosecution filed a proposed order for $62,241.28 in restitution. Roberson's counsel objected and asked for additional time to review the numbers underlying the proposed amount. The court offered a hearing date outside the ninety-one-day statutory deadline in section 18-1.3-603(1)(b), C.R.S. (2024), to make a final determination of the restitution amount. Roberson's counsel accepted that date.

¶2 The question we answer here is whether Roberson's acceptance of a hearing date outside the ninety-one-day statutory deadline constituted a voluntary waiver of a statutory right. We conclude that it did.

I. Facts and Procedural History

¶3 Roberson formerly worked for a car dealership. During the time she was employed at the dealership, she apparently forged her name on four business checks and used the company credit card to make several unauthorized purchases. She pleaded guilty to felony counts of forgery and theft, misdemeanor criminal mischief, and a probation violation. At the time of sentencing, the victim had determined the value of certain elements of these offenses but told the prosecution he needed more time to go through records to determine what other losses might be directly attributable to Roberson's conduct. The plea agreement, which was part of the sentence, therefore provided that the "parties

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Department of Health v. Donahue
690 P.2d 243 (Supreme Court of Colorado, 1984)
People v. Rediger
2018 CO 32 (Supreme Court of Colorado, 2018)
on v. People
2020 CO 46 (Supreme Court of Colorado, 2020)
Finney v. People
2014 CO 38 (Supreme Court of Colorado, 2014)
The People of the State of Colorado v. Benjamin Weeks
2021 CO 75 (Supreme Court of Colorado, 2021)
Elliott J. Forgette v. The People of the State of Colorado.
2023 CO 4 (Supreme Court of Colorado, 2023)
The People of the State of Colorado v. Jessica Jo Roberson.
2025 CO 30 (Supreme Court of Colorado, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 CO 30, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-people-of-the-state-of-colorado-v-jessica-jo-roberson-colo-2025.