Colby Ray Ballinger v. State, 405 S.W.3d 346

Ballinger was charged with aggravated sexual assault of a child and pleaded guilty on December 15, 2009, under deferred adjudication for five years.
The deferred adjudication order initially assessed $205 in court costs.
In July 2012 the State moved to proceed to final adjudication; the court found true the allegations, revoked supervision, and adjudicated Ballinger guilty, sentencing him to 20 years without a fine and ordering costs.
The judgment adjudicating guilt later assessed $505 in court costs, but the certified bill of costs was not in the record at that time; a bill of costs was added after Ballinger filed briefing.
The court allowed supplementation of the record to include the bill of costs, citing Rule 34.5(c) and Article 103.006, and rejected a due process objection to after-the-fact supplementation.
On appeal, the court held the $505 figure insufficiently supported, but the listed fees were statutory, so it modified the judgment to reflect $205 in court costs and amended Attachment A accordingly.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for $505 costs	Ballinger	Ballinger	Costs $505 not supported; reduce to $205.
Allowance of post-judgment supplementation	Ballinger	Record supplementation allowed	Supplementation appropriate and not a due process violation.

Johnson v. State, 389 S.W.3d 513 (Tex. App.—Houston [14th Dist.], pet. granted) (no indication the bill existed at trial; guidance on supplementation timing)
Reyes v. State, 324 S.W.3d 865 (Tex. App.—Amarillo 2010, no pet.) (modification of judgment and withholding when costs are challenged on appeal)