State v. M. Reynolds, 2017 MT 317

Reynolds was convicted after trial of felony DUI (fourth or subsequent) and two misdemeanors; he does not challenge guilt but appeals the judgment imposing fines, surcharges, prosecution costs, public defender fees, and court tech fees.
PSI and subsequent financial disclosures showed limited income: 2015 joint income $19,144, Social Security deposits, recent part‑time work history (maintenance and welding), modest assets and vehicle loans, $500 monthly rent.
At sentencing the District Court delayed to obtain public defender billing ($5,829) and updated financial information; Reynolds testified he was not currently employed, subsists on Social Security, and could do limited welding if he had a license.
The District Court found Reynolds "fit, able to work, earn money," relied on PSI, testimony, and financial documents, and imposed statutory fines plus discretionary costs including the full public defender fee, various surcharges, a victim surcharge, prosecution costs, and three $10 court information technology fees.
Reynolds appealed, arguing the court failed to adequately determine his ability to pay (and chilled his right to jury trial by imposing public defender fees after trial) and that the written judgment improperly increased the oral sentence by adding misdemeanor surcharges and duplicative court tech fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court adequately determined Reynolds’s ability to pay before imposing fines, fees, prosecution costs, and public defender fees	State argued the court made a scrupulous, meticulous inquiry using the PSI, testimony, documents, and found Reynolds could pay over time	Reynolds argued the court failed to make the required detailed inquiry, relied on outdated PSI, ignored Social Security limits, and chilled his jury‑trial right by imposing full public defender costs after trial	Court affirmed: inquiry was scrupulous and meticulous; district court did not abuse discretion in imposing fees (ability to pay found based on testimony, PSI, and finances)
Whether written judgment improperly increased oral sentence by adding misdemeanor surcharges and duplicative court tech fees	State conceded some additions were clerical errors	Reynolds argued the written judgment included surcharges and multiple $10 tech fees not imposed at sentencing	Court reversed in part: struck two $15 misdemeanor surcharges and reduced three $10 court tech fees to a single $10 user fee; remanded to correct judgment

State v. McLeod, 2002 MT 348 (district must make a "serious inquiry and separate determination" of ability to pay before imposing fines)
State v. Gable, 2015 MT 200 (court satisfied scrupulous/meticulous ability‑to‑pay inquiry by relying on PSI, testimony, and financial questioning)
State v. Moore, 2012 MT 95 (failure to question defendant or acknowledge PSI means court did not make required inquiry into ability to pay)
State v. Pope, 2017 MT 12 (court information technology fee is imposed per user, not per conviction)