People v. Sanders, 296 Mich. App. 710

Sawyer, J. addresses whether trial courts must precisely calculate court costs under MCL 769.1k(l)(b)(ii).
Defendant pleaded guilty to delivery of <50 g heroin, second offense; sentence included $1,000 in court costs and other costs.
Defendant challenges the $1,000 court costs as lacking a factual basis; argues court abused discretion.
Trial court denied a motion to correct sentence, insisting statute imposes costs without requiring a detailed delineation.
Court recognized authority to impose costs under the statute and noted a broad, flat-fee approach is permissible.
Court remands to establish a factual basis for the $1,000 figure or adjust it, while preserving a general reasonableness standard for felony costs in the county

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must costs be calculated exactly for each case?	Defendant argues costs require precise per-case calculation.	Defendant argues no exact calculation is mandated.	No exact per-case calculation required.
Must the trial court provide a concrete basis for the general costs figure?	Defendant seeks detailed justification for the general figure used.	Defendant contends insufficient factual basis was shown for the $1,000 figure.	Court must provide a more concrete basis for the general costs figure on remand.
Is a flat-rate or overhead-inclusive approach permissible for court costs?	Defendant relies on need for precise costs relationship.		Flat-fee/ reasonable-flat approach permitted; overhead can be considered.

People v Lloyd, 284 Mich App 703 (2009) (recognizes prior cost-imposition framework in Michigan appellate context)
People v Wein, 382 Mich 588 (1969) (discusses basis for imposition of costs in earlier era)
People v Dilworth, 291 Mich App 399 (2011) (discusses relation between costs of prosecution and expenses; supports reasonableness standard for court costs)
Teasdale v. State, 335 Mich 1 (1952) (limits on costs bearing unrelated public expenditures; not controlling for court costs here)