Criminal

Trial court was not required to conduct indigency hearing before assessing fines, costs, and fees as condition of probation, but it must do so at some point before completion of probation or before revoking probation for failure to pay.
Trial court lacked authority to impose substance-abuse or drug-countermeasures fees.
Trial court abused its discretion in ordering defendant to return to school and maintain “C” average while being employed full-time; statute permits either maintaining full-time employment or “faithfully pursu[ing]” a course of study to equip him for employment.

Smell of burnt marijuana, observed during exigent-circumstance entry into apartment, did not provide probable cause for search warrant when officer did not explain why he concluded smell was not from neighboring apartment; and seizure of key fob for vehicle where large bundles of marijuana were found exceeded scope of warrant’s authorization for “indicia of occupancy, residency or ownership.” State failed to prove K-9 sniff of vehicle would have been conducted independent of the tainted evidence. Because bundles of marijuana were poisoned fruit and should have been suppressed, conviction was reversed.