California, United States of America
The following excerpt is from The People v. Bennett, C061721, No.08-1098 (Cal. App. 2010):
2. At least one court has indicated that an "express finding" of unusual circumstances is required to overcome the presumption that a defendant sentenced to state prison does not have the ability to reimburse defense costs. (People v. Lopez, supra, 129 Cal.App.4th at p. 1537.)
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