Amanda Vaughn v. State of Indiana
982 N.E.2d 1071
Ind. Ct. App.2013Background
- Amanda Vaughn pled guilty to Class A misdemeanor criminal trespass; other charges were dismissed.
- The plea agreement gave the trial court discretion over fines and costs.
- The trial court sentenced Vaughn to 165 days, with 151 days suspended, and found Vaughn indigent.
- The court ordered forty hours of community service in lieu of fines and costs, with a jail-day-for-downtime sanction for incomplete service.
- Vaughn objected, arguing lack of authority under the plea, potential incarceration for indigency, and equal protection concerns.
- The trial court vacated the costs/fines order and again imposed forty hours of community service in lieu of costs and fines.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion imposing community service in lieu of fines and costs | Vaughn argues the plea agreement prohibited it and violated indigent protections | State argues community service is a permissible, statutorily authorized substitute if allowed by statute | Reversed and remanded for lack of statutory authority |
Key Cases Cited
- Freije v. State, 709 N.E.2d 323 (Ind. 1999) (probation conditions may be imposed when permitted by the plea agreement)
- Jackson v. State, 968 N.E.2d 328 (Ind.Ct.App.2012) (discretion to impose community service depends on plea terms)
- Whedon v. State, 765 N.E.2d 1276 (Ind. 2002) (fines or costs may be imposed on indigent defendants in some circumstances)
- Banks v. State, 847 N.E.2d 1050 (Ind.Ct.App.2006) (costs may not be imposed when a convicted person is indigent)
- Bennett v. State, 802 N.E.2d 919 (Ind. 2004) (plea agreement binds trial court to sentencing provisions)
- Berry v. State, 950 N.E.2d 798 (Ind.Ct.App.2011) (sentencing decisions including fines/costs are within trial court discretion)