State v. Harris, 2020 Ohio 3056

Travonte Harris pled no contest to felonious assault and having weapons while under disability; court sentenced him to five years and imposed $1,037 in court costs.
At sentencing the court stated it had considered Harris’s present and future ability to pay; it did not impose fines or restitution but ordered court costs and permitted community-service credit toward costs.
Harris filed pro se letters/motions claiming indigency (earning $18/month in prison, paying for meds and hygiene, $2 medical copays) and asserting court costs were effectively uncollectible; he requested waiver or a $3/month payment plan.
The trial court denied Harris’s post-conviction motion to waive or stay costs and reiterated the option to perform community service; the denial contained no explanation that it had considered Harris’s present or future ability to pay.
The appellate court reversed and remanded, holding the trial court abused its discretion by failing to consider and explain whether Harris could pay; the court upheld the trial court’s refusal to deem the costs uncollectible because prison-account garnishment and community service made collection feasible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused its discretion by denying Harris’s motion to waive or stay court costs without considering his present or future ability to pay and without explaining its reasoning	The State conceded the trial court should explain and consider ability to pay on a postconviction waiver motion; trial court had previously considered ability to pay at sentencing	Harris argued the trial court failed to consider his indigency and did not explain the denial, preventing meaningful appellate review	Reversed and remanded: trial court abused its discretion by not considering Harris’s present/future ability to pay and not explaining its decision
Whether the court should have waived costs as uncollectible under R.C. 2303.23	The State argued collection remains feasible (prison-account garnishment and community-service credit) so costs are not uncollectible	Harris argued lack of payments for years made the debt uncollectible and subject to cancellation	Overruled: trial court did not abuse its discretion in declining to cancel costs; collection methods remain available

State v. White, 817 N.E.2d 393 (recognizes trial court must impose court costs against convicted defendants)
State v. Snowden, 140 N.E.3d 1112 (addresses mandatory imposition of court costs)
State v. Darmond, 986 N.E.2d 971 (standard for abuse of discretion explained)
State v. Threatt, 843 N.E.2d 164 (permits DRC deductions from inmate accounts to satisfy judgments)
State v. Dunson, 134 N.E.3d 1227 (appellate decision addressing need to consider ability to pay on postconviction motions)
State v. Taylor, 106 N.E.3d 65 (same)
State v. Sibrian, 128 N.E.3d 232 (requires trial court explanation when denying postconviction cost-relief motions)