as neither necessary nor incidental to the trial, was a $1 library fee to be collected in certain counties expressly for the creation and maintenance of law libraries in those counties 2d 608, 613 (1968) (explaining legislature could not circumvent the explicit provision of the constitution by placing the label “costs” on items that were clearly not costs of court), with Broyles v. State, 285 Ark. 457, 688 S.W.2d 290, 292 (1985) (hold ing that a cost charged to a criminal defendant convicted of driving while intoxicated to support programs relating to drunken driving, detoxification services, and alcohol and drug abuse rehabilitation was constitutional since funds go to agencies created to keep the highways safe from drunk drivers); and State v. Young, 238 So.2d 589, 589-90 (Fla.1970) (<HOLDING>). It is therefore likely that the Carson Court
holding that a district court may not rely on a charging document without first establishing that the crime charged was the same crime for which the defendant was convicted holding punishment must be proportional to the crime convicted holding that a statute imposing a one dollar court cost for law enforcement on every person convicted of a crime was not a violation of the separation of powers doctrine because it is reasonable that one convicted of a crime should be made to share in the improvement of agencies that society has had to employ in defense against the very acts for which he has been convicted holding that the right to counsel in probation revocation proceedings is not absolute where the defendant has been convicted of or has admitted to committing a crime holding that before the accessory to a crime can be convicted as such it must be shown that the crime has been committed by the principal