State v. Lewandowski
In State v. Lewandowski, 220 Ariz. 531,15, 207 P.3d 784, 789 (App. 2009) the Court held that A.R.S. 13-805, which governs the entry of CROs, applies only at the expiration of a defendant's sentence or probation.
The Court reasoned the imposition of a CRO before the defendant's probation or sentence has expired "constitutes an illegal sentence, which is necessarily fundamental, reversible error," because the premature accrual of interest obligates the defendant to pay more than 13-805 requires. Id.
Section 13-805 has been amended three times since Lane committed the offenses here. See 2012 Ariz. Sess. Laws, ch. 269, 1; 2011 Ariz. Sess. Laws, ch. 263, 1, ch. 99 4.
The Court refered to the version in effect at the time of her offenses, see 2005 Ariz. Sess. Laws, ch. 260, 6, but observe that, on these facts, the result would be the same under the current version.