State v. Dees, 2025 Ohio 294

Nathan Dees was convicted in four separate cases involving felonies between November 2023 and February 2024, leading to consecutive 12-month prison sentences.
Dees was appointed counsel in each case due to indigency.
At sentencing, the trial court imposed a $30 financial sanction in each case ($120 total) under R.C. 2743.70, finding the sanction to be non-waivable.
The court waived other fines and costs to help Dees make restitution but did not waive these financial sanctions.
Dees did not object to the sanctions during sentencing but appealed, arguing they should have been waived due to indigency.

Issue	Dees's Argument	State's Argument	Held
Whether imposition of financial sanction under R.C. 2743.70 was error due to indigency	Trial court should waive $30 sanctions because Dees was indigent and had appointed counsel	The statute does not require waiver for indigent defendants, and a finding of indigency for counsel is distinct from ability to pay costs	No error: Court could conclude Dees could pay, based on age, health, education, and work history

State v. Long, 53 Ohio St.2d 91 (plain error requires outcome would have been different)
State v. Perry, 101 Ohio St.3d 118 (burden on appellant to prove plain error)
State v. Willis, 2012-Ohio-294 (court may infer ability to pay fine from presentence report)