Christopher L. Richards v. State of Indiana (mem. dec.), 84A04-1611-CR-2660

Richards pled guilty in 2011 to Class B felony dealing in methamphetamine; total sentence 10 years with 2 years suspended to probation.
Probation began April 21, 2015, with a condition prohibiting nonprescribed controlled substances.
Probation officer sought drug treatment modification; court ordered counseling.
State alleged Richards tested positive for meth/amphetamines on 22 occasions; Richards admitted the violations at the revocation hearing.
Richards evaded arrest for several months; testified he had brief periods of sobriety, attended NA, and cared for an ill mother.
Trial court revoked probation and ordered Richards to serve the remaining two-year suspended sentence in prison.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation and execution of suspended sentence was an abuse of discretion	State: court acted within discretion to revoke after multiple positive drug tests and evasion	Richards: court should have imposed less restrictive sanction given family hardship and treatment efforts	Court affirmed: no abuse of discretion in ordering incarceration

Sparks v. State, 983 N.E.2d 221 (Ind. Ct. App. 2013) (probation is a privilege; revocation reviewed for abuse of discretion)
Prewitt v. State, 878 N.E.2d 184 (Ind. 2007) (trial court has leeway after granting probation)
Heaton v. State, 984 N.E.2d 614 (Ind. 2013) (abuse of discretion standard defined)
Pierce v. State, 44 N.E.3d 752 (Ind. Ct. App. 2015) (affirmation if revocation supported by substantial evidence)
Woods v. State, 892 N.E.2d 637 (Ind. 2008) (two-step probation revocation process)
Berry v. State, 904 N.E.2d 365 (Ind. Ct. App. 2009) (no detailed statement required when reinstating part of imposed sentence)
Castillo v. State, 67 N.E.3d 661 (Ind. Ct. App. 2017) (no written statement required showing consideration of alternatives on revocation)