State v. Webb, 2015 Ohio 3318

Appellant Burke Webb, Jr. was charged with Trafficking in Drugs (3rd degree) and bound over to the Richland County Common Pleas Court.
Webb pleaded guilty to the second count of the indictment as part of a plea agreement; judgment reflecting the plea change filed June 27, 2014.
Sentencing occurred August 6, 2014; a judgment entry imposing sentence was filed August 7, 2014.
Webb filed a Financial Disclosure/Affidavit of Indigency after sentencing.
Webb moved to waive the mandatory fine; the trial court denied the motion on October 7, 2014.
Webb sought delayed appeal, challenging the denial of the indigency affidavit and the mandatory fine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the mandatory $5,000 fine was properly imposed	Webb asserts indigence; no prior indigency affidavit before sentencing defeats imposition.	State contends the affidavit post-sentencing does not prevail; indigency not shown pre-sentencing.	Affirmed; mandatory fine valid since no pre-sentencing indigency affidavit.

State v. Gipson, 80 Ohio St.3d 626 (1998) (mandates indigency-based waiver procedure for fines)
State v. Slagle, 2013-Ohio-230 (5th Dist. Richland No. 12CA62, 2013) (res judicata; court cannot vacate valid final judgment except void/clerical errors)
State v. Perry, 10 Ohio St.2d 175 (1967) (pre-sentencing procedures for indigency and fines)
State v. Knox, 2013-Ohio-1662 (8th Dist. Cuyahoga) (affidavit of indigency does not automatically waive fines)
State v. Ficklin, 2013-Ohio-3002 (8th Dist. Cuyahoga) (abuse of discretion standard in indigency-fine determinations)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse-of-discretion principle)