Cases | People v. Duvall, 908 P.2d 1178 (Colo. Ct. App. 1995) | 2018

Defendant pled guilty to possession of a controlled substance and theft, arising from his removal of controlled substances from the drug store where he was employed. The trial court ordered defendant to pay restitution in an amount representing the value of the controlled substances and employee time spent conducting inventories, installing security equipment, and cooperating with law enforcement. On appeal, defendant claimed that the trial court erred in awarding restitution for employee time where the company expended no funds in addition to regular salaries. The appellate court held that the value of employee time was properly included in the restitution award regardless of whether the company expended funds in addition to regular salaries. Actual pecuniary damages are not limited to out-of-pocket expenditures but encompass other losses or injuries that can reasonably be calculated and recompensed in money.

(This case cites former Colo. Rev. Stat. § 16-11-204.5.)