State v. Risner

Citations

• 2025 Ohio 1218

Syllabus

R.C. 2941.51(D); Court-Appointed-Counsel Fees; Civil Assessment; Future Ability to Pay; Abuse of Discretion; State v. Taylor, 2020-Ohio-6786. A trial court may not order a defendant to pay court-appointed-counsel fees as a part of his or her sentence. Rather, a trial court may issue a civil assessment for court-appointed-counsel fees. A trial court may, pursuant to R.C. 2941.51(D), assess some or all of the court-appointed-counsel fees incurred during a defendant's representation. A trial court may assess court-appointed-counsel fees if the defendant is found to have a present or future ability to pay these costs. Appellate courts review the imposition of court-appointed-counsel fees as a civil assessment under an abuse of discretion standard.