Dees v. State

In Dees v. State, 865 S.W.2d 461, 462 (Tex. Crim. App. 1993), a bail bondsman appealed an order awarding the State a percentage of the bond amount plus interest and costs. Id. at 461. As to costs, the bail bondsman claimed "civil court costs are not authorized in a bail bond forfeiture proceeding" and argued "only those court costs normally associated with criminal cases may be assessed." Id. at 462. The court of criminal appeals disagreed. Looking to the language of article 22.10, the court held "civil court costs may be assessed in a bail bond forfeiture proceeding after entry of the judgment nisi." Id. (citing TEX. CODE CRIM. PROC. ANN. art. 22.10). Thus, at the trial court level, civil costs of court may be collected in bond forfeiture proceedings. See Dees, 865 S.W.2d at 462.