Clay P. Manvilla v. State of Indiana (mem. dec.), 03A04-1610-CR-2445

Defendant Clay P. Manvilla pleaded guilty to Class D felony theft and received a two-year executed sentence suspended to probation with a 30-day county jail term and various community-corrections conditions.
Manvilla had an extensive juvenile adjudication history and prior probation difficulties.
Multiple probation petitions were filed for fee nonpayment and an arrest for illegal consumption; earlier alleged violations resulted in extension of probation and placement in 30 days of work release.
While in work release, Manvilla made physical contact with a residential officer while attempting to reach a smoking area; the work-release program discharged him as unsuccessful.
At a revocation hearing Manvilla admitted the probation violation; the trial court revoked probation and ordered execution of the balance of his suspended two-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by ordering execution of the full suspended sentence after revoking probation	State: Court may execute suspended sentence after finding violation; sanction appropriate given history and recommendation of work-release director	Manvilla: Court abused discretion by not giving weight to his admission, rehabilitative efforts, and the minor nature of the violation	Court affirmed: No abuse of discretion; court may order execution of suspended sentence and is not required to balance mitigating/aggravating factors at revocation beyond allowing mitigation evidence

Prewitt v. State, 878 N.E.2d 184 (2007) (probation is discretionary; supports revocation and execution of suspended sentence)
Heaton v. State, 984 N.E.2d 614 (2013) (standard of review for probation revocation is abuse of discretion; two-step revocation process)
Woods v. State, 892 N.E.2d 637 (2008) (admission of violation permits proceeding to sanction phase but probationer must be allowed to present mitigating evidence)
Treece v. State, 10 N.E.3d 52 (2014) (single violation can justify revocation; courts need not balance mitigating/aggravating factors when executing an existing sentence)
Anglemyer v. State, 868 N.E.2d 482 (2007) (sets requirements for sentencing, not for probation revocation)
Anglemyer v. State, 875 N.E.2d 218 (2007) (clarification on sentencing procedures)
Puckett v. State, 956 N.E.2d 1182 (2011) (trial court should not relitigate original plea's leniency in revocation proceedings)
Mitchell v. State, 619 N.E.2d 961 (1993) (probation revocation enforces an already-imposed sentence)
Goonen v. State, 705 N.E.2d 209 (1999) (courts have discretion to execute suspended sentence following probation revocation)