How have courts considered the ability of a defendant to pay in the context of the use of prison wages?

In People v. Hennessey (1995) 37 Cal.App.4th 1830, 1837, the court held the ability to pay includes a defendant's ability to pay in the future, such as the earning of prison wages. In People v. Frye (1994) 21 Cal.App.4th 1483, 1487, the court found that the trial court could consider both the defendant's present ability and the ability to pay in the future through the use of prison wages. Moreover, Government Code section 70373, and Penal Code sections 1202.4, subdivision (b) and 1465.8, say nothing about the current ability to pay.