State v. Heier

CourtOhio Court of Appeals
DecidedMay 29, 2026
DocketL-25-00252
StatusPublished

This text of State v. Heier (State v. Heier) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Heier, (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Heier, 2026-Ohio-2022.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State of Ohio Court of Appeals No. L-25-00252

Appellee Trial Court No. CR0202500257

v.

Rachel Heier DECISION AND JUDGMENT

Appellant Decided: May 29, 2026

*****

Julia R. Bates, Lucas County Prosecuting Attorney, and Angelina Wagner, Assistant Prosecuting Attorney, for appellee.

Laurel A. Kendall, for appellant.

***** MAYLE, J.

{¶ 1} Defendant-appellant, Rachel Heier, appeals the October 2, 2025 judgment of

the Lucas County Court of Common Pleas, convicting her of child endangering,

sentencing her to a prison term of 36 months, and ordering her to pay the “costs of supervision, confinement, assigned counsel, and prosecution.” For the following reasons,

we affirm, in part, and reverse, in part.

I. Background

{¶ 2} Rachel Heier entered a plea of no contest to one count of child endangering,

a violation of R.C. 2919.22(A) and (E)(2)(c), a third-degree felony. The trial court

accepted the plea, made a finding of guilty, ordered a presentence investigation, and

continued the matter for sentencing. At the sentencing hearing, the trial court sentenced

Heier to a prison term of 36 months and up to two years’ discretionary post-release

control. After finding that Heier had the present or future ability to pay, the court

imposed “the applicable costs of supervision, confinement, assigned counsel, and

prosecution as authorized by law.”

{¶ 3} Heier appealed. She assigns the following error for our review:

The trial court improperly assigned financial sanctions when it found appellant had, or reasonably may be expected to have, the ability to pay all or part of the applicable costs of supervision, confinement, and assigned counsel, all of which are discretionary costs, without finding that appellant had the ability to pay.

II. Law and Analysis

{¶ 4} Heier challenges the trial court’s imposition of discretionary costs, including

the “costs of supervision, confinement, and assigned counsel.” The costs of supervision

are inapplicable here given that Heier was sentenced to prison, not community control.

See State v. Velesquez, 2023-Ohio-1100, ¶ 12 (6th Dist.), citing R.C. 2951.021(A)(1). We

address the costs of confinement and assigned-counsel fees separately because while

2. courts have discretion to impose the costs of confinement and assess assigned-counsel

fees, the former constitutes a part of Heier’s sentence, while the latter does not.

A. Costs of Confinement

{¶ 5} Heier argues that the trial court erred in imposing the costs of confinement.

She acknowledges that the court “arguably made a conclusory finding” at the sentencing

hearing regarding her ability to pay the costs of confinement, but she claims that “there

was no discussion” of her employment status outside the fact that she lost her part-time

job, and there was “no indication of her income, employment skills or educational level.”

{¶ 6} Under R.C. 2929.18(A)(5)(a)(ii) and (E), a trial court may require an

offender to pay all or part of the costs of confinement if it finds that he or she is able to

pay, or is likely in the future to be able to pay. The court need not conduct a formal

hearing to determine the defendant’s ability to pay, and it need not explain its findings on

the record. State v. Ivey, 2021-Ohio-2138, ¶ 8 (6th Dist.). We review a trial court

judgment imposing the costs of confinement under R.C. 2953.08(A)(4) and (G)(2)(b) and

will reverse if we find that the imposition of these costs was contrary to law. State v.

Patterson, 2024-Ohio-2198, ¶ 11 (6th Dist.).

{¶ 7} The trial court explicitly found that Heier has or is reasonably expected to

have the means to pay the costs of confinement. It did so orally at the sentencing

hearing, then it incorporated this finding into its sentencing entry. As indicated above,

the trial court was not required to state the basis for its finding. In fact, this court has

explained that a trial court’s indication that it reviewed a PSI that includes information

3. about the defendant’s financial, educational, and vocational background may support its

imposition of discretionary costs. Id., citing State v. Cantrill, 2020-Ohio-1235, ¶ 91 (6th

Dist.).

{¶ 8} Here, Heier stated at the plea hearing that she attended college for four

years. At the sentencing hearing, her attorney advised the court that Heier “is self-

employed with a pallet business,” and was working for Walmart as a “Spark driver” at the

time of the offense. The PSI—which the court clearly read—indicates that Heier was 39

years old at the time of sentencing, is in good physical health, owns a pallet business that

generates income, was working as a Walmart Spark driver, and has several years of

college education. She was sentenced to 36 months in prison, so she will be only 42

years old upon her release. The record indicates that Heier lost her job with Walmart

because of her conviction, however, her age, health status, education, and employment

history all suggest that Heier will be employable after her release from prison and,

therefore, able to pay the costs of confinement. The imposition of these costs was not

contrary to law.

B. Appointed-Counsel Costs

{¶ 9} As for the assessment of appointed-counsel fees, Heier again argues that the

trial court made only “a conclusory finding that [she] would have the ability to pay such

costs in the future,” and she complains that the court pointed to nothing in the record to

support its finding.

4. {¶ 10} Under R.C. 2941.51(D), the fees and expenses of appointed counsel “shall

be paid by the county” and “shall not be taxed as part of the costs.” Having said this, the

trial court has authority to assess appointed-counsel fees upon a defendant if the

defendant “has, or reasonably may be expected to have, the means to meet some part of

the cost of the services rendered to the person[.]” State v. Taylor, 2020-Ohio-6786, ¶ 24;

R.C. 2941.51(D). It may do so “without making specific findings on the record to justify

the fee assessment.” Id. at ¶ 2.

{¶ 11} An order to pay appointed-counsel fees “is not part of the criminal

sentence.” Id. at ¶ 37. While these fees may be imposed at the sentencing hearing, they

should be imposed in a separate entry. Id. at ¶ 32. “[I]f the assessment of the fees is

included in the sentencing entry, the court must note that the assessment of the court-

appointed-counsel fees is a civil assessment and is not part of the defendant’s sentence.”

Id. Because the assessment of these fees is not part of a defendant’s sentence, “we do not

review the issue under R.C. 2953.08 for appeals based on felony sentencing.” State v.

Radabaugh, 2024-Ohio-5640, ¶ 79 (3d Dist.), appeal not allowed, 2025-Ohio-231.

Rather, we employ an abuse-of-discretion standard of review. Id. See also Taylor at ¶ 41

(DeWine, J. concurring) (signaling that proper standard of review is abuse of discretion).

{¶ 12} Here, as previously explained, the trial court explicitly found that Heier has

or reasonably may be expected to have the means to pay all or part of the assigned-

counsel fees, and the record supports this finding. But the trial court failed to comply

5.

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Related

State v. Cantrill
2020 Ohio 1235 (Ohio Court of Appeals, 2020)
State v. Taylor (Slip Opinion)
2020 Ohio 6786 (Ohio Supreme Court, 2020)
State v. Ivey
2021 Ohio 2138 (Ohio Court of Appeals, 2021)
State v. Rose
2022 Ohio 3529 (Ohio Court of Appeals, 2022)
State v. Velesquez
2023 Ohio 1100 (Ohio Court of Appeals, 2023)
State v. Patterson
2024 Ohio 2198 (Ohio Court of Appeals, 2024)
State v. Radabaugh
2024 Ohio 5640 (Ohio Court of Appeals, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Heier, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-heier-ohioctapp-2026.