State ex rel. Wood v. Christiansen

While R.C. 2941.51 requires payment for services to assigned counsel, division (A) thereof affords discretion to the trial court by limiting such payment to “such compensation and expenses as the trial court may approve.” Respondent concedes that his reason for not approving the subject application for fees was that the application was not filed pursuant to Local Rule 17.06 which requires that such application be filed within thirty days of sentencing.

The question is whether the thirty-day time limitation for filing attorney fee applications imposed by Local Rule 17.06 is unreasonable in view…