California, United States of America
The following excerpt is from The People v. Powell, C063029, No. 080802 (Cal. App. 2010):
"'P]roceedings to assess attorney's fees against a criminal defendant involve the taking of property, and therefore require due process of law, including notice and a hearing.' [Citations.]" (People v. Phillips (1994) 25 Cal.App.4th 62, 72; see People v. Flores (2003) 30 Cal.4th 1059, 1062-1063.)
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