problems. See maj. op. 146, n.5; Toland, 364 P.2d at 593 (concluding the "summary, hasty, middle of the night justice" dispensed to a suspected drunk driver after a crash did not comport with due process). By distinguishing To-land, the majority sets up two tiers of invalid convictions: There are stark constitutional violations, like those in Toland, that demand setting the defendant back to the status quo ante, and then there are arguably less egregious but nonetheless invalid convictions, like Nelson's, for which reimbursement is unavailable. But reversal is reversal. And an invalid conviction is no conviction at all. T61 Other courts have' recognized what the interests of justice compel in similar circumstances. See United States v. Hayes, 385 F.3d 1226, 1229-30 (Oth Cir.2004) (<HOLDING>); Telink Inc. v. United States, 24 F.3d 42, 47
holding that where juror did not disclose that she had an interest in the conviction of the defendant probable prejudice is shown and the conviction must be reversed holding that where the defendants conviction was reversed on collateral review the government must return amounts paid as special  assessments and costs though it need not reimburse for restitution disbursed after the conviction became final holding resentencing does not affect the date on which the judgment  of conviction became final holding that for sentencing purposes the government does not need to allege a defendants prior conviction or prove the fact of a prior conviction where that fact is not an element of the present crime holding that where a conviction is reversed after trial the double jeopardy clause does not bar a government appeal that if successful would only reinstate the conviction and would not subject defendant to a second trial