Commonwealth v. Steadman
Annotate this CaseAfter a jury trial, Defendant was convicted of theft by deception and being a second-degree persistent felony offender. At the sentencing hearing, the trial court stated that a hearing with testimony would be necessary to determine the proper amount of restitution. Defendant did not object to this. The trial court then entered final judgment sentencing Defendant to imprisonment. Ten days later, the court ordered restitution. Defendant did not object to the court's power to order restitution during the restitution hearing. Defendant subsequently moved to vacate his conviction and the restitution order. The trial court denied the motion. The court of appeals vacated the restitution order, concluding that the trial court lost subject-matter jurisdiction to enter the restitution order ten days after the entry of the final judgment sentencing Defendant to imprisonment. The Supreme Court reversed, holding that the trial court had subject-matter jurisdiction over the question of restitution, and Defendant waived any other claims regarding restitution by failing to raise that issue to the trial court.
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