State v. Dylla

Court-appointed attorney fees are properly imposed against a defendant if the court finds on the record that the defendant's employment history, prospects for future employment, education level, ability to meet financial obligations, fee amount, and short jail sentence support a reasonable inference that defendant can or will be able to pay off the fee.

Defendant appealed three weapons-related convictions from the trial court, arguing only that the trial court improperly imposed court-appointed attorney fees. On appeal, the State responded that the court found on the record that Defendant held an associate's degree, the fine was a mere $260, Defendant had a long working history, Defendant had a mere 30-day jail sentence, Defendant had valid future employment prospects, and Defendant had maintained his monthly financial obligations of $691 in child support. The State argued that these findings were sufficient to prove that Defendant had the ability to pay the court-appointed attorney fee of $260. The Court agreed. Affirmed.