STATE OF ARIZONA v. JOSEPH E. DUSTIN, AZ Court of Appeals, CA-CR 18-0399 8-27-2019 A time payment fee in a criminal case cannot be imposed when there was no corresponding penalty, fine, or sanction to trigger a statutory authorization of the (delayed) time payment fee.  The statute provides:
A.R.S. ยง 12-116(A): " In addition to any other assessment authorized by law, a fee of twenty dollars shall be assessed on each person who pays a court ordered penalty, fine or sanction on a time payment basis, including parking penalties, restitution and juvenile monetary assessments. A time payment basis shall be any penalty, fine or sanction not paid in full on the date the court imposed the fine, penalty or sanction. Notwithstanding any other law, the time payment fee shall be collected first after restitution. A judge may not waive or suspend a time payment fee."