Cory L. Meadows v. State of Indiana
2014 Ind. App. LEXIS 29
| Ind. Ct. App. | 2014Background
- Meadows was charged with Class D felony theft and Class A misdemeanor conversion, later adding two counts of Class D felony theft; he pled guilty to both theft counts in a combined plea and received a three-year aggregate sentence with pretrial credit and with the remainder suspended on probation.
- A deferral of judgment and sentence was pursued under Indiana's problem-solving drug court program, with Meadows agreeing to participate and seeking dismissal of charges and probation violations upon successful program completion.
- Meadows entered the county drug court program in 2012 under the deferral, with the understanding that successful completion would result in dismissal of the charged offenses and fines/probation consequences.
- In March 2013 the State petitioned to terminate Meadows from the drug court program due to multiple violations, including positive drug tests and failure to comply with program rules; Meadows admitted violations but sought credit for time served on electronic monitoring.
- The trial court denied Meadows' request for credit time and terminated his drug court participation, sentencing him in accordance with the original plea agreement; Meadows appealed challenging the denial of credit time.
- The court held that Meadows’ time on electronic monitoring occurred under a deferral program, not as probation or post-conviction confinement, and thus credit statutes applicable to probation or sentencing did not apply; the denial of credit time was within the court’s discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Meadows is entitled to credit time for electronic monitoring. | Meadows | Meadows | Discretionary denial upheld |
| Whether statutes on home detention, community corrections, or pretrial credit apply to a deferral drug court program. | Meadows relies on §35-38-2.5-5 and §35-38-2.6-6 | Those statutes do not apply to deferral program electronically monitored time | Statutes do not apply to deferral program time |
| Whether Brown v. State effectively limits the court’s discretion to deny credit time in deferral contexts. | Meadows | Brown is distinguishable and does not compel credit in deferral | Brown not controlling; discretion remains |
| Whether Meadows’ status during drug court participation qualifies as awaiting trial or sentencing for credit purposes. | Meadows claims §35-50-6-3 applies | Deferral program time does not fit awaiting trial or sentencing | Not awaiting trial or sentencing; credit not available |
Key Cases Cited
- Molden v. State, 750 N.E.2d 448 (Ind. Ct. App. 2001) (pre-sentence jail time credit is statutory; otherwise discretionary)
- Peterink v. State, 971 N.E.2d 735 (Ind. Ct. App. 2012) (credit for time spent on home detention; distinguishable from deferral program)
- Brown v. State, 957 N.E.2d 666 (Ind. Ct. App. 2011) (drug treatment restrictiveness; not directly about credit in deferral contexts)