Is there any case law where a defendant has been found to be indigent in a criminal case?

As a final argument, Tzakis contends that the court's order requiring him to pay the costs of prosecution under 28 U.S.C. Sec. 1918(b) is unconstitutional because of his indigency. We find no merit in this contention because at the relevant time, the time of sentencing, Tzakis did not claim to be indigent; on the contrary, he was still represented by retained counsel. Thus, the court did not abuse its discretion in imposing costs on him. See United States v. Gering, 716 F.2d 615, 626 (9th Cir.1983). Should Tzakis be unable, due to indigency, to pay these costs, the government simply would not be able to collect them, and it could not punish Tzakis further for his inability to pay. Bearden v. Georgia, 103 S.Ct. at 2070.