Brent A. Mechling v. State of Indiana
16 N.E.3d 1015
| Ind. Ct. App. | 2014Background
- Mechling charged with strangulation (D felony), invasion of privacy (D), domestic battery (A misdemeanor), and battery resulting in bodily injury (D); he pled guilty to invasion of privacy with other charges dismissed.
- Plea agreement left sentencing to the trial court and included a waiver of the right to appeal.
- At sentencing on November 26, 2013, Mechling received a 3-year sentence; the court advised him he could appeal after sentence, and no objection was made by State or defense.
- Mechling appeals challenging the sentence as inappropriate.
- Court holds the waiver of appellate rights valid and rejects estoppel; affirming the sentence and declining to address appropriateness of the sentence due to the valid waiver.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Estoppel from enforcing waiver due to erroneous advisement | Mechling argues State’s silence estops enforcement | State is not estopped; advisement did not affect plea | No estoppel; waiver enforceable |
| Sentence appropriateness given offense and character | Mechling claims sentence is inappropriate | Waiver enforces appellate bar; review waived | Not addressed; waiver dispositive; sentence affirmed |
Key Cases Cited
- Creech v. State, 887 N.E.2d 73 (Ind. 2008) (erroneous advisements on waived rights do not void the plea)
- Brattain v. State, 891 N.E.2d 1055 (Ind. Ct. App. 2008) (trial court advisement after plea does not affect plea transaction)
- Town of New Chicago v. City of Lake Station ex. rel. Lake Station Sanitary Dist., 939 N.E.2d 638 (Ind. Ct. App. 2010) (silence does not create estoppel absent duty to speak)