State Of Washington v. Isaiah White, 48178-2

Isaiah Cee White pleaded guilty to possession of heroin with intent to deliver within 1,000 feet of a school bus route stop and was sentenced to 54 months.
At sentencing defense counsel asked the court to waive or reduce legal financial obligations (LFOs): $2,000 drug fund, $1,000 attorney fee, $500 fine, and $200 court fee.
Counsel and White reported limited recent work (telemarketing ~30 hrs/week earlier that year), physical ailments (hernia, rotator cuff), and existing debts; counsel argued these facts affect ability to pay.
The judge questioned White about education, employment, and physical limitations, concluded White could perform telemarketing-type work, and declined to waive LFOs.
The judgment states the court considered White’s past, present, and future ability to pay and found he had the ability to pay the imposed LFOs.
White appealed, arguing the court failed to conduct the individualized inquiry required by RCW 10.01.160(3) and Blazina; he also opposed prospective appellate costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court conducted required individualized inquiry into defendant’s ability to pay LFOs	White: court did not sufficiently inquire into current and future ability to pay under RCW 10.01.160(3) and Blazina	State: record shows discussion of financial resources, medical expenses, employment, and future earning ability; court considered these before imposing LFOs	Court held the record shows the necessary individualized inquiry; no remand for LFOs
Whether appellate costs should be precluded because defendant cannot pay	White: objects to appellate costs citing inability to pay	State: may file a cost bill; preservation addressed by Grant; costs determined post-appeal under RAP 14.2	Court referred appellate costs to a commissioner for consideration if State files a bill; preservation preserved

State v. Blazina, 182 Wn.2d 827 (2015) (requires sentencing court to consider defendant’s individual financial circumstances and make an individualized inquiry into current and future ability to pay LFOs)
State v. Lundy, 176 Wn. App. 96 (2013) (identifies certain mandatory fees not subject to ability-to-pay inquiry)
State v. Baldwin, 63 Wn. App. 303 (1991) (abuse of discretion standard for imposition of LFOs when statutory compliance is shown)
State v. Johnson, 96 Wn. App. 813 (1999) (statutory compliance reviewed de novo)
State v. Sinclair, 192 Wn. App. 380 (2016) (discusses appellate costs and ability to pay)
State v. Mathers, 193 Wn. App. 913 (2016) (distinguishes mandatory LFOs from discretionary LFOs subject to ability-to-pay analysis)