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[a defendant] receives after a new trial.’ [ North Carolina v. Pearce, 395 U.S. 711, 725(II)(C) (23 L.Ed.2d 656, 89 S.Ct. 2072) (1969). ‘In order to assure the absence of such a motivation, we have concluded that whenever a judge imposes a more severe sentence upon a defendant after a new trial, the reasons for his doing so must affirmatively appear. Those reasons must be based upon objective information concerning identifiable conduct on the part of the defendant occurring after the time of the original sentencing proceeding. And the factual data upon which the increased sentence is based must be made part of the record, so that the constitutional legitimacy of the increased sentence may be fully reviewed on appeal.’ Id. at 726(II)(C); see also Anthony v. Hopper, 235 Ga. 336, 337(1) (219 S.E.2d 413) (1975). And an increase in time served amounts to an ‘increased sentence’ for due process purposes. Blake v. State, 272 Ga.App. 402, 406(1) (612 S.E.2d 589) (2005) (presumption of vindictiveness applies where trial court revoked probation of five-year sentence at resentencing); Edge v. State, 194 Ga.App. 466, 467 (391 S.E.2d 18) (1990); Inman v. State, 124 Ga.App. 190, 192(1) (183 S.E.2d 413) (1971). Having committed reversible error at Schlanger's first sentencing hearing, and having reimposed the original sentence before it had jurisdiction to do so, this trial court presided over a third sentencing proceeding at which it increased the amount of time Schlanger was to serve and threatened to increase it once again if he took another appeal. This was rank error .” Blake v. State, 272 Ga.App. 402, 612 S.E.2d 589 (March 23, 2005). Defendant pled guilty to eight counts, including kidnapping, then successfully appealed to withdraw the plea to kidnapping due to lack of venue. On remand, the trial court increased the sentence for one of the remaining counts (serious injury by vehicle), but the overall sentence was reduced. Defendant again appeals, contending that the trial court should not have increased the sentence for serious injury by vehicle. Held, the presumption of vindictiveness applies when sentence on a given count is increased after appeal, even if the aggregate sentence is not increased, unless the record on re-sentencing includes objective facts explaining the reason for the increase. Exception: changing formerly concurrent counts to consecutive does not raise a presumption of vindictiveness; see Duffey v. State , 222 Ga.App. 802, 476 S.E.2d 89 (1996). Controlling: North Carolina v. Pearce , 395 U.S. 711, 89 S.Ct. 2072, 23 L.Ed.2d 656 (1969); Anthony v. Hopper , 235 Ga. 336, 219 S.E.2d 413 (1975) (presumption of vindictiveness where new sentence same as old sentence, but one count increased). “Compare Staley v. State, 233 Ga.App. 597, 599 (505 S.E.2d 491) (1998) (a change in the conditions of probation is not necessarily an increase in sentence).” Trial judge’s statement on record here that resentencing was not intended to punish for appealing was insufficient to “set forth objective information justifying the increased sentence, such as any new conduct by Blake, a change in circumstances, or any other reason as is required under Pearce . [Cit.]” Bernes, concurring specially, argues for an “aggregate package” approach, as used by a majority of federal circuits, comparing the aggregate new sentence with the aggregate original sentence. Bernes also notes the 11 th Circuit’s approach, comparing the aggregate new sentence with the aggregate sentence on the same charges , not including any charges reversed on appeal. Stuart v. State, 267 Ga.App. 463, 600 S.E.2d 629 (May 18, 2004). “In Allen v. State, [193 Ga.App. 670, 388 S.E.2d 889 (1989)] we ruled that if the ‘trial court did impose a ‘harsher’ sentence than it otherwise may have been inclined to impose had [defendant] accepted the plea bargain, there was no unconstitutional ‘vindictiveness’ in so doing.” Accord, Benjamin v. State , 269 Ga.App. 232, 603 S.E.2d 733 (August 23, 2004). XX. RESTITUTION 1. ABILITY TO PAY Tobias v. State, 319 Ga.App. 320, 735 S.E.2d 113 (November 30, 2012). Vehicular homicide and related convictions affirmed; victim restitution was properly ordered. “Although the trial court did not make findings on the record as to Tobias' financial situation, we have held that ‘it is unnecessary to require the ordering authority to make a finding on each factor,’” citing McCart v. State, 289 Ga.App. 830, 832(1), 658 S.E.2d 465 (2008), and Turner v. State, 312 Ga.App. 799, 804(2), 720 S.E.2d 264 (2012). In re: W.J.F., 302 Ga.App. 361, 691 S.E.2d 271 (February 15, 2010). No abuse of discretion where trial court found that juvenile was able to pay restitution: “there was testimony that W.J.F. worked occasionally and earned approximately $20 a yard cutting grass during the summer. The juvenile court also considered psychological reports which showed average intelligence and no mental impairments that would prevent W.J.F. from working. In fact, the psychologist opined that W.J.F. would benefit from ‘part-time employment.’ Further, the court made accommodations for W.J.F.'s age by deferring the payment of restitution until he turned sixteen.” Order to pay $100 per month restitution thus was supported by evidence. Wimpey v. State, 297 Ga.App. 182, 676 S.E.2d 831 (March 30, 2009). Trial court’s restitution order affirmed by 6-1 majority; defendant was given opportunity to present evidence as to her ability to pay, but “failed to

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