The Ohio Court of Appeals has upheld a lower court's decision to impose court costs on Angie McIntire after she pleaded guilty to several drug-related charges. This ruling affects McIntire and others in similar situations, emphasizing the court's authority to impose costs regardless of a defendant's financial status.

On October 6, 2026, the court ruled in case numbers 26-COA-002 and 26-COA-003, affirming the Ashland County Court of Common Pleas' decision regarding McIntire's sentencing. This case highlights important aspects of sentencing in drug-related offenses and the responsibilities of defendants regarding court costs.

Background

Angie McIntire was indicted on September 12, 2025, on multiple charges, including aggravated possession of drugs, driving under suspension, and possessing criminal tools. The charges stemmed from two separate cases: Case No. 25-CRI-136 and Case No. 25-CRI-164. McIntire initially pleaded not guilty to all charges.

However, on December 1, 2025, she changed her plea to guilty for several counts in both cases. The trial court sentenced her immediately after the plea hearing, imposing a total of 24 months in prison, with some sentences to be served concurrently and others consecutively. While the court waived mandatory fines due to her indigency, it ordered her to pay court costs.

The Ruling

In its ruling, the Ohio Court of Appeals, led by Judge Craig R. Baldwin, stated that the trial court did not err in imposing court costs. The court explained, "R.C. 2947.23(A)(1)(a) directs that in every criminal case the court 'shall include in the sentence the costs of prosecution' and must 'render a judgment against the defendant for such costs.'" This ruling reinforces the idea that courts are required to impose costs on all convicted defendants, regardless of their financial situation.

The court also noted that while a trial court has discretion to waive or suspend costs, it is not obligated to consider a defendant's ability to pay when imposing those costs. The court stated, "A trial court is not required to consider the defendant's ability to pay under R.C. 2947.23(C), though it is permitted to do so." This emphasizes the court's authority and discretion in sentencing, particularly regarding financial obligations.

Impact

This ruling has significant implications for defendants in Ohio facing similar circumstances. It clarifies that even if a defendant is found to be indigent, the court can still impose costs as part of the sentence. This decision aligns with previous rulings in similar cases, such as State v. Rouse, which established that courts have the authority to impose costs without needing to consider a defendant's financial situation.

The court's decision may also influence future cases, as it sets a precedent that reinforces the obligation of defendants to bear the costs associated with their prosecution. This could lead to more defendants facing financial burdens post-sentencing, even if they are unable to pay.

What's Next

McIntire has the option to appeal this decision, but the court's ruling leaves little room for argument regarding the imposition of court costs. There are no related cases pending that would directly affect this ruling. However, similar cases may arise in the future, prompting further examination of the court's authority to impose costs on indigent defendants.