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Id. As to the 1st factor in the balancing examination, the Court docket stated that there was an "apparent desire" within a refund of cash paid like a consequence of convictions that were no more valid. Id. An overturned conviction restores the presumption of innocence, the Courtroom reported, erasing any State claim to money paid out in the shape of prices, charges, or restitution. Id. at 1255-56. Concerning the next aspect, the Court docket declared that the act's need that defendants demonstrate their innocence by clear and convincing evidence established a threat of erroneous deprivation of your defendants' interest inside of a refund in their money. Id. at 1256. After the presumption of innocence is restored, "defendants should not be saddled with any proof burden." Id. As towards the third factor, the Court mentioned that Colorado had "zero claim of right" to funds paid only like a consequence of subsequently invalidated convictions. Id. at 1257. Under the Courtroom's Keeping in Nelson, id. at 1252, the Point out is obligated under the because of process clause of the Fourteenth Modification to refund monies exactly where a few components are contented: (one) the monies have been "exacted through the defendant" on conviction and being a consequence of the conviction; (two) the amounts "exacted" were being in fact paid by the defendant; and (3) the conviction has Page 785

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