In the 1973 case Fuller v. Oregon, the United States Supreme Court upheld an Oregon statute that required convicted defendants with sufficient financial resources to repay part or all of their court-appointed attorney fees. The defendant, Gary James Fuller, had been provided a state-funded lawyer during his trial for forgery and was later ordered to reimburse $500 in legal costs after being found guilty. He appealed this decision on grounds that it violated his Sixth Amendment right to counsel and Fourteenth Amendment rights against self-incrimination and due process. However, the Supreme Court ruled 8-1 in favor of Oregon's law as constitutional because it only applied to those who were able - without hardship - to pay back these expenses over time; thus not infringing upon any individual’s constitutional rights.

In the dissenting opinion for Fuller v. Oregon, Justice William O. Douglas argued that requiring a defendant to repay court-appointed attorney fees as part of probation was unconstitutional. He believed this requirement violated the Equal Protection Clause because it discriminated against poor defendants who could not afford their own legal representation and were therefore more likely to be burdened with debt following their trial. Furthermore, he contended that such a requirement might deter individuals from exercising their right to counsel out of fear of incurring additional financial obligations they would struggle to meet post-trial, thus undermining the Sixth Amendment's guarantee of legal representation for all criminal defendants regardless of wealth or income level.