Amber Keith v. State of Indiana, 91 N.E.3d 1029

Amber Keith was placed on 180 days of home detention and ordered to remain at home except for probation appointments and device maintenance.
On March 6, 2017 she was fitted with a GPS-enabled ankle monitoring device and instructed by a home detention officer to "go directly home."
Keith visited multiple locations instead of returning straight home, eventually returned around noon, left again, and later had her anklet lose power from ~5:00 p.m. to ~11:15 p.m., during which officers could not confirm her location.
The State charged Keith under Ind. Code § 35-44.1-3-4(c) for failure to return to lawful detention after temporary leave (a Level 6 felony).
The trial court found she was granted temporary leave to return to her home from the home detention office and failed to do so, convicting her of escape and ordering 180 days incarceration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a home under home detention qualifies as a "place of lawful detention" for escape statutes	Home is lawful detention; Keith failed to return as ordered	Keith: the anklet/electronic monitoring, not the home, is the detention; she never left the device behind	Court: Home is a place of lawful detention for those on home detention; conviction affirmed

Anglin v. State, 787 N.E.2d 1012 (Ind. Ct. App. 2003) (court order placing a person in a location can create "lawful detention" for escape)
Grabarczyk v. State, 772 N.E.2d 428 (Ind. Ct. App. 2002) (home detention requires the person to stay at home)
Hickman v. State, 81 N.E.3d 1083 (Ind. Ct. App. 2017) (factors for confinement include freedom of movement, supervision, and autonomy)
Boss v. State, 702 N.E.2d 782 (Ind. Ct. App. 1998) (prosecutors have broad discretion in charging decisions)
Gordon v. State, 981 N.E.2d 1215 (Ind. Ct. App. 2013) (escape and unauthorized absence statutes are distinct; prosecution choice is permitted)