Aaron T. Coleman v. State of Indiana (mem. dec.), 49A02-1704-CR-670

Coleman was charged with level 6 felony theft and initially assessed a $100 Supplemental Public Defender Fee at his first hearing.
He pleaded guilty and was sentenced on March 21, 2016.
On March 8, 2017, at a probation-violation-related hearing, the trial court questioned Coleman about finances and expressly stated it would find him "indigent to any outstanding balances."
Despite that oral finding, the written sentencing order from March 8, 2017, assessed a $100 supplemental public defender fee.
Coleman appealed the imposition of the fee as an abuse of discretion given the court’s indigency finding.
The Court of Appeals reversed and remanded for an amended sentencing order reflecting the court’s indigency determination and eliminating the fee.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by imposing a $100 supplemental public defender fee after finding defendant indigent	State: the March 8 order already relieved Coleman of outstanding obligations; appeal is moot	Coleman: fee was improperly imposed because the court found him indigent to outstanding balances at the hearing	Court: Reversed — the court abused its discretion by assessing the fee in the written order and remanded for an amended sentencing order

Langdon v. State, 71 N.E.3d 1162 (Ind. Ct. App. 2017) (appellate review of fee imposition limited to abuse-of-discretion and statutory bounds)
Banks v. State, 847 N.E.2d 1050 (Ind. Ct. App. 2006) (public defender fee improper where defendant found indigent)
Mosley v. State, 908 N.E.2d 599 (Ind. 2009) (mootness analysis where effective relief remains possible)