What is the test for express or implied finding that a defendant has the ability to pay attorney fees pursuant to section 987.8?

A finding that a defendant has the ability to pay attorney fees pursuant to section 987.8, may be express or implied based upon the conduct and content of the hearings. (People v. Phillips (1994) 25 Cal.App.4th 62, 71 superseded by statute on another issue in People v. Trujillo (2015) 60 Cal.4th 860 (Trujillo).) Whether the findings are express or implied, the order must be supported by substantial evidence. (People v. Nilsen (1988) 199 Cal.App.3d 344, 347.)

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