DES MOINES, Iowa — The Iowa Supreme Court ruled 5-2 on January 9, 2026, that low-income defendants cannot be ordered to pay for court-appointed attorney costs when criminal charges are dismissed.

The decision in State v. Ronald Pagliai vacated improper cost orders and remanded the case. Ronald Pagliai faced four theft and resisting arrest charges in Polk County. He pleaded guilty to two theft counts in a plea deal; prosecutors dismissed the other two. The agreement required Pagliai to pay nearly $500 in costs—including $329.85 for indigent defense—in the dismissed cases.

The court held no Iowa statute authorizes assessing such costs in dismissed cases. Authority to do so was repealed in 2012. Justice Christopher McDonald wrote for the majority: where no statute allows costs in dismissed cases, the order exceeds court authority and is invalid.

The ruling protects indigent defendants—determined unable to afford private counsel—from reimbursing the state for public defender services when not convicted. The ACLU of Iowa, which filed an amicus brief, called the practice fundamentally unfair, especially for those exercising their right to counsel.

The state conceded no statutory basis existed. The court declined to reach constitutional claims. On remand, the state may enforce the plea without the unauthorized costs or vacate the entire agreement and potentially reinstate dismissed charges.

The decision reinforces that dismissed charges carry no financial penalty for court-appointed representation.


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