People v. Hollis.

2025 CO 54. No. 23SC834. Restitution—Money Advanced by Law Enforcement Agencies—Extraordinary Direct Public Investigative Costs—Buy Money—CRS § 18-1.3-602—People v. Juanda—Teague v. People.

September 8, 2025

The supreme court held that unrecovered “buy money” used to purchase illegal drugs from a suspect during an undercover transaction is neither “money advanced by a law enforcement agency” under CRS § 18-l.3-602(3)(a) nor an “extraordinary direct public investigative cost” under CRS § 18-1.3-602(3)(b). Accordingly, the court concluded that the People were not entitled to restitution for the unrecovered buy money under either statutory provision. Because the court of appeals reached the same result, albeit on slightly different grounds, the  court affirmed the judgment vacating the restitution order.