Hearne v. State, 2013 Tex. App. LEXIS 11627

Hearne pleaded guilty to a felony (injury to a child) without an agreed punishment; the trial court sentenced him to 15 years and ordered $234 in court costs.
On appeal Hearne challenged the sufficiency of the evidence supporting the court costs due to the absence of a bill of costs in the appellate record.
The record initially lacked a certified bill of costs; the court later ordered supplementation with a costs bill.
The appellate record was supplemented with a document titled J.I.M.S. Supplemental Costs Bill Assessment detailing each cost.
The court held the costs were supported by sufficient evidence, consisting of statutorily mandated costs documented in the record.
The concurrence discusses Anders-related concerns about appellate review and the role of counsel in presenting merits issues, but the dispositive decision affirms the trial court’s judgment on costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for court costs	Hearne argues there is no certified bill of costs in the record.	Hearne's counsel did not present meritorious issues; costs may be assessed independently of a bill in the judgment.	Sufficient evidence supports the costs; judgment affirmed.

Mayer v. State, 309 S.W.3d 552 (Tex.Crim.App.2010) (sufficiency review for cost awards remains in light of record evidence)
Cardenas v. State, 403 S.W.3d 377 (Tex.App.Houston [1st Dist.] 2013) (costs supported by statutory framework and record evidence)
In re Daniel, 396 S.W.3d 545 (Tex.Crim.App.2013) (post-conviction context; costs/attorney’s fees not necessarily tied to merits of conviction)
Armstrong v. State, 340 S.W.3d 759 (Tex.Crim.App.2011) (costs can be assessed and not required to be in judgment; may be documented post-judgment)
Owen v. State, 352 S.W.3d 542 (Tex.App.-Amarillo 2011) (costs supported by statutory scheme and record evidence)
Tommy Thomas v. State, — (—) (not included due to lack of official reporter citation)