Background

• On May 5, 2012, Darrell A. Williams caused significant damage to another vehicle in Tippecanoe County and drove away; a witness photographed his plate and the rental records linked the car to Williams.
• Police discovered Williams’ driving privileges had been suspended for life; he was charged with operating a motor vehicle after lifetime forfeiture (Class C felony) and failure to stop after an accident resulting in property damage (Class C misdemeanor).
• Williams requested a jury trial but pleaded guilty on the morning of trial after jurors were seated; he later failed to appear for post-plea hearings and fled the state for over two years until arrested in Chicago.
• At sentencing the court imposed an aggregate five-year sentence: two years executed in DOC, one year community corrections, two years suspended on probation; the misdemeanor sentence (60 days) ran concurrently.
• Williams appealed, arguing his sentence was inappropriate under Indiana Appellate Rule 7(B); the State defended the sentence based on Williams’ extensive criminal history and conduct.

Issues

Key Cases Cited

• Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (establishes standard of review for sentencing and appellate review authority)
• Anglemyer v. State, 875 N.E.2d 218 (Ind. 2007) (clarification on sentencing review framework)
• Gibson v. State, 43 N.E.3d 231 (Ind. 2015) (Appellate Rule 7(B) review aims to correct outlier sentences, not to reweigh every case)
• Keller v. State, 987 N.E.2d 1099 (Ind. Ct. App. 2013) (factors for assessing sentence appropriateness include culpability, severity, and harm)
• Williams v. State, 51 N.E.3d 1205 (Ind. Ct. App. 2016) (character of the offender may be assessed broadly and prior convictions are relevant)