State v. Brock, 2021 Ohio 1279

Julie Brock pleaded guilty to fifth-degree felony drug possession in two Adams County cases and the cases were consolidated on appeal. The court ordered a presentence investigation (PSI).
The PSI reported Brock receives SSI/disability (about $550–$587/month), has health problems, no steady work history, but owns a home on 6.9 acres (potentially in foreclosure).
At sentencing the court imposed two $1,500 fines (one per case), ordered payment of prosecution costs and supervision fees, and imposed community-control sanctions including jail time and reporting requirements.
The trial court orally and in its entries found Brock had "past, present and future" ability or potential to satisfy the financial sanctions and ordered $25/month payments on each fine (Brock had suggested $20).
Brock appealed, arguing the fines were unlawful because the court failed to properly consider her present/future ability to pay under R.C. 2929.19(B)(5), and that court costs should have been waived or cancelled due to inability to pay.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Brock)	Held
Imposition of fines	Fines are lawful: within statutory maximum and the trial court considered ability to pay (PSI + explicit finding).	Fines are contrary to law: court failed to consider present/future ability to pay; Brock is indigent and cannot pay.	Affirmed — fines within statutory limits; record (PSI and explicit findings) shows the court considered ability to pay; R.C. 2953.08(G)(2) does not authorize vacatur on the basis Brock urges.
Imposition of court costs	Costs properly imposed; trial court satisfied statutory duty to enter costs and retains discretion re: waiver/cancellation.	Court abused discretion by not waiving/cancelling costs given inability to pay; Brock lacks present/future ability.	Affirmed — costs are mandatory entry; Brock forfeited waiver/cancellation claim by not moving below and did not raise plain error on appeal; statutes permitting waiver/cancellation are permissive and do not require consideration of ability to pay.

State v. Lykins, 102 N.E.3d 503 (4th Dist.) (low standard for inquiry into ability to pay; PSI can suffice to show consideration under R.C. 2929.19(B)(5))
State v. Smith, 97 N.E.3d 1068 (10th Dist.) (supports that minimal on-record inquiry meets R.C. 2929.19(B)(5))
State v. Taylor, 163 N.E.3d 486 (Ohio 2020) (trial court not required to consider ability to pay when deciding waiver/suspension/cancellation of costs under R.C. 2947.23(C) or R.C. 2303.23)
State v. Fannon, 117 N.E.3d 10 (4th Dist.) (plain-error standard requires obvious error that affects substantial rights)
State v. Long, 372 N.E.2d 804 (Ohio 1978) (plain-error relief is exceptional and applied with utmost caution)