State v. Pinto
In State v. Pinto, 179 Ariz. 593, 594-95, 880 P.2d 1139, 1140-41 (App. 1994), the defendants challenged the jurisdiction of the trial court to enter judgments on restitution orders after their probationary terms expired. Id. at 594, 880 P.2d at 1140.
They argued that the phrase "at the time the defendant completes the defendant's period of probation or the defendant's sentence" in the second sentence of the statute was jurisdictional in nature and that the expiration of their probation divested the trial court of continuing jurisdiction over them. Id. at 595-96, 880 P.2d at 1141-42.
In affirming the judgments entered against them, this court held that "the words 'at the time defendant completes his or her period of probation . . .' are not jurisdictional, but are merely advisory as to when the trial court is to act." Id. at 596, 880 P.2d at 1142.