People of the State of Colorado v. Hoover, 2005 WL 674642 (Colo. App. March 24, 2005) held that a post-conviction bond pending appeal can be "cash only." The defendant was convicted of multiple counts of securities fraud and sentenced to 100 years in prison. He applied for bond pending appeal, and the trial court set it at $1 million cash only. He asked the appellate court to allow a $1 million surety bond. The Court held that the constitutional right to bail applied only prior to conviction and that release on bond pending appeal was purely a question of statute. The statute gave the trial court considerable discretion to deny bail or to set conditions including personal recognizance, security by cash or deposit of property or security by an approved surety. The trial court's decision was not an abuse of discretion and was affirmed.