Brock J. Mathews v. State of Indiana (mem. dec.)
84A01-1701-CR-69
| Ind. Ct. App. | Jun 20, 2017Background
- Brock J. Mathews pled guilty to Level 6 carrying a handgun without a license and received a five-year sentence: three years on work release and two years suspended to probation.
- Mathews completed a Jail Linkage program and began pre-trial work release; he later failed to return to placement and admitted the probation violation at a revocation hearing.
- At the revocation hearing the State also proved Mathews had committed two new offenses while on placement: resisting law enforcement and battery.
- Mathews testified he left placement after self-medicating with methamphetamine to manage panic attacks and trauma related to his step‑mother’s murder, and he requested placement in a treatment program.
- The trial court revoked his placement/probation and ordered execution of the previously suspended two‑year term in the DOC, directing placement in the CLIFF mental health program with possible modification out after successful completion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by ordering Mathews to serve his suspended sentence after revoking probation | State: Revocation and execution of suspended sentence appropriate given violation(s) and new offenses | Mathews: Court should have placed him in a community treatment program for addiction/trauma rather than impose suspended time | Court affirmed: no abuse of discretion; sanction appropriate and court afforded treatment opportunity in CLIFF program |
Key Cases Cited
- Prewitt v. State, 878 N.E.2d 184 (Ind. 2007) (probation is discretionary and revocation may impose suspended sentence)
- Sanders v. State, 825 N.E.2d 952 (Ind. Ct. App. 2005) (abuse-of-discretion standard for probation sanction review)
- Sparks v. State, 983 N.E.2d 221 (Ind. Ct. App. 2013) (two-step probation revocation process and need for mitigating evidence)
- Pierce v. State, 44 N.E.3d 752 (Ind. Ct. App. 2015) (single probation violation can support revocation)
- Johnson v. State, 62 N.E.3d 1224 (Ind. Ct. App. 2016) (revocation of community corrections treated like probation revocation)