California, United States of America
The following excerpt is from People v. Bowden, C060038 (Cal. App. 8/10/2009), C060038. (Cal. App. 2009):
An order to pay public defender fees cannot be upheld on review unless it is supported by substantial evidence. (People v. Nilsen (1988) 199 Cal.App.3d 344, 347.)
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