Sam Wiley, Jr. v. State, 390 S.W.3d 629

Wiley was convicted of hindering apprehension; sentenced to eight years' imprisonment and a $1,000 fine, with the sentence suspended and Wiley placed on eight years of community supervision.
One term of supervision required Wiley to reimburse the county $400 for court-appointed attorney fees; later, the State moved to revoke supervision and the trial court revoked it, imposing an eight-year term and a $1,000 fine.
The revocation judgment included $800 in attorney's fees: $400 originally assessed for the supervision and $400 for the revocation proceedings.
Wiley challenged the sufficiency of the evidence to support the second $400 revocation-attorney’s-fee assessment; the State conceded error on that portion but not on the original $400.
The court followed Price v. State to hold that a party waives the complaint about the original $400 if not raised when the supervision was imposed.
The court reversed in part on the revocation-fees issue and remanded for entry of a new judgment consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the revocation-attorney’s-fee assessment is supported by the evidence	Wiley	Wiley	Insufficient evidence; reverse in part
Whether the complaint about the original $400 fee was waived	Wiley	State	Waived; not preservable on revocation appeal

Mayer v. State, 309 S.W.3d 552 (Tex. Crim. App. 2010) (attorney's fees must be supported by evidence at imposition)
Speth v. State, 6 S.W.3d 530 (Tex. Crim. App. 1999) (preservation of complaint about fee imposition timing)