Christopher Reid v. State of Indiana (mem. dec.), 16A01-1611-CR-2554

On Dec. 10, 2015, Christopher Reid was stopped for impeding traffic and found driving with suspended privileges as a habitual traffic violator (HTV). He was arrested and charged with operating as an HTV; the State also alleged habitual-offender status.
On Sept. 20, 2016, Reid pled guilty to the Level 6 HTV offense and admitted the habitual-offender allegation without a plea agreement.
The trial court imposed maximum term for the Level 6 felony (2.5 years) and the minimum habitual-offender enhancement (2 years), for an aggregate 4.5-year sentence: four years executed in the DOC and six months suspended to probation.
Reid appealed under Indiana Appellate Rule 7(B), arguing the sentence is inappropriate in light of the nature of the offense and his character; he also disputed the lawfulness of the traffic stop but waived that claim by pleading guilty.
The sentencing calculus considered statutory ranges (Level 6: 6 months–2.5 years; habitual-offender enhancement: additional 2–6 years), Reid’s asserted necessity defense (driving to a court date because others were unable/safe to drive), and his extensive criminal history spanning violent and nonviolent convictions and repeated probation violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Reid’s 4.5-year sentence is inappropriate under App. R. 7(B)	State: sentence is within statutory range and supported by Reid’s record	Reid: sentence is excessive given the minor nature of the traffic offense and claimed necessity to drive	Court: sentence not inappropriate; deferential review; Reid’s extensive criminal history supports the sentence
Whether the traffic stop’s legality affects the plea/sentence	State: not at issue because plea waived stop challenge	Reid: argued stop illegal (but waived)	Court: stop challenge waived by guilty plea; cannot be raised on appeal

Knapp v. State, 9 N.E.3d 1274 (Ind. 2014) (appellate authority for sentence-review power)
Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (appellate rule authorizes sentence revision only for inappropriate sentences)
Inman v. State, 4 N.E.3d 190 (Ind. 2014) (standard for App. R. 7(B) review)
Conley v. State, 972 N.E.2d 864 (Ind. 2012) (deferential nature of sentencing review)
Bethea v. State, 983 N.E.2d 1134 (Ind. 2013) (factors informing appropriateness: culpability, severity, harm)
Chambers v. State, 989 N.E.2d 1257 (Ind. 2013) (App. R. 7(B) aims to address outlier sentences)
King v. State, 894 N.E.2d 265 (Ind. Ct. App. 2008) (clarifies inquiry: whether imposed sentence is inappropriate, not whether another sentence is preferable)