State v. Moreno-Medrano
In State v. Moreno-Medrano, 218 Ariz. 349, P 16, 185 P.3d 135, 140 (App. 2008), the Court was asked to decide whether the trial court had erred by reducing an order to pay nonpunitive attorney fees and indigent administrative fees to a CRO at the time of sentencing.
There, however, the defendant, who had failed to object below, did not argue on appeal that the error was fundamental, and the Court found his claim waived. Id. P 17.
Nonetheless, in dicta the Court expressed skepticism that an illegal sentence could result from the entry of a CRO for nonpunitive fees the trial court was otherwise entitled to impose. Id.