State v. Stoutamire, 2020 Ohio 4533

In 2007 Stoutamire was convicted (jury) of multiple felonies and sentenced to an aggregate 34-year prison term; the sentence included an order that he "shall pay the cost of prosecution."
In March 2020 Stoutamire, incarcerated, filed a Motion to Waive Court Costs, claiming the costs were uncollectible given his inability to pay.
The trial court did not waive costs; instead it established a $5/month payment plan for the outstanding court costs.
Stoutamire appealed, raising two assignments of error: (1) the trial court failed to make findings of fact, and (2) the trial court abused its discretion by denying the motion to waive costs.
The Eleventh District affirmed: findings are not required when the statute is silent, a court may but need not consider ability to pay, and ordering a modest monthly payment was not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by not making findings of fact when ruling on motion to waive costs	State: no statutory requirement for findings; record suffices for review	Stoutamire: court should have made factual findings and determined collectibility	Court: findings not required; appellate review still possible; assignment rejected
Whether the trial court abused its discretion by denying waiver and ordering $5/month payments	State: court may fashion remedy under R.C. 2947.23(C); payment plan reasonable and collectible via prison-collection procedures	Stoutamire: costs are uncollectible and should be waived due to inability to pay	Court: ability to pay is not required to be considered; ordering modest monthly payments was within discretion and not an abuse; affirmed

State v. Threatt, 108 Ohio St.3d 277 (2006) (abuse-of-discretion standard for waiver of costs and permitting state collection methods including prison-account deductions)
State v. White, 103 Ohio St.3d 580 (2004) (trial court must assess costs against convicted defendants; waiver is permitted but not required)
State v. Braden, 158 Ohio St.3d 462 (2019) (trial court retains continuing jurisdiction to waive, suspend, or modify payment of costs)
State v. Riley, 141 N.E.3d 531 (11th Dist. 2019) (statute does not require factual findings when ruling on motion to waive court costs)
Agricultural Ins. Co. v. Constantine, 144 Ohio St. 275 (1944) (appellate courts affirm correct judgments regardless of erroneous reasons)
State ex rel. Cassels v. Dayton City School Dist. Bd. of Edn., 69 Ohio St.3d 217 (1994) (same principle regarding judgments versus reasons)