Benton Lee Courtney, Jr. v. State of Indiana (mem. dec.), 48A02-1604-CR-864

Courtney pleaded guilty to possession of methamphetamine (Level 5 felony), maintaining a common nuisance (Level 6 felony), and theft (Class A misdemeanor); received a three-year sentence suspended to probation per plea agreement.
Less than one month into probation, Alexandria police observed Courtney driving recklessly (crossing double-yellow lines, 70 mph in a 20 mph zone, failing to stop twice), and laughing during a high-speed chase through a residential area.
Courtney stopped; occupants included his mother (front passenger) and a passenger with two children under two in the back seat.
After arrest, occupants told officers Courtney was trying to get his mother to a hospital for seizures; paramedics arrived and the mother denied having a seizure.
The State alleged probation violations including resisting law enforcement (Level 6), neglect of a dependent (Level 6), and criminal recklessness (Level 6), and noted Courtney tested positive for methamphetamine/amphetamine.
At the probation revocation hearing Courtney admitted the failed drug test and asserted necessity (he was forced to drive to get his mother to a hospital); the trial court found his necessity claim not credible, revoked probation, and ordered execution of the full suspended sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in rejecting necessity as a defense to the conduct underlying the probation violation	State: court may reject necessity if evidence disproves at least one element; credibility is for factfinder	Courtney: drove to hospital to prevent greater harm (necessity); lacked other alternatives	Court: affirmed — trial court reasonably found necessity not believable and not objectively reasonable; no reweighing of credibility
Whether the trial court abused its discretion by ordering Courtney to serve his entire previously suspended sentence	State: facts (new felonies, drug use, endangering children) support full sentence	Courtney: first violation, admitted drug test saving time, cooperative — does not warrant full sentence	Court: affirmed — imposition of full suspended sentence was within discretion given egregious facts and safety risk

Prewitt v. State, 878 N.E.2d 184 (Ind. 2007) (probation is discretionary and revocation reviewed for abuse of discretion)
Heaton v. State, 984 N.E.2d 614 (Ind. 2013) (standards for appellate review of probation revocation)
Toops v. State, 643 N.E.2d 387 (Ind. Ct. App. 1994) (elements of the necessity defense)
Dozier v. State, 709 N.E.2d 27 (Ind. Ct. App. 1999) (necessity burden and fact-finder’s role in disproving defense)
Pointer v. State, 585 N.E.2d 33 (Ind. Ct. App. 1992) (State must disprove defensive claim beyond a reasonable doubt in criminal trials)
Cozart v. State, 897 N.E.2d 478 (Ind. 2008) (abuse of discretion includes misinterpretation of law)
Axsom v. Axsom, 565 N.E.2d 1097 (Ind. Ct. App. 1991) (abuse of discretion may be shown when trial court misinterprets law or disregards statutory factors)