California, United States of America
The following excerpt is from People v. Zabala, C090631 (Cal. App. 2020):
4. In his opening brief, defendant argued under People v. Dueas (2019) 30 Cal.App.5th 1157, the trial court's imposition of non-penal fines without determining defendant's ability to pay violated due process. In response, the People argued defendant forfeited this claim by failing to raise it in the trial court. Defendant expressly abandons this argument in his reply.
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