Denielle R. Pharr v. State of Indiana, 2013 Ind. App. LEXIS 650

Pharr pleaded guilty to OVWI and resisting law enforcement; sentenced to 18 months in work release with 18 months probation.
She was placed in a community corrections program (work release) as part of the sentence.
Petition to revoke work release filed February 27, 2013 based on violations including medication misuse, not seeking employment, drug test results, and unpaid fees.
Trial court held a hearing, found violations, and ordered the balance of sentence to be served in prison; also ordered loss of 155 days of good time credit while in work release.
Pharr was awarded credit for 155 days actually served in the work release program but later appealed the denial of credit time for time served in work release.
Court reverses and remands for corrected abstract of judgment consistent with the ruling on credit time.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had authority to deprive credit time	Pharr argues the trial court lacked authority	Pharr contends only DOC may deprive credit time	Trial court exceeded authority; reverse and remand

Campbell v. State, 714 N.E.2d 678 (Ind. Ct. App. 1999) (trial court cannot deprive earned credit; initial determination by DOC was improper)
Robinson v. State, 805 N.E.2d 783 (Ind. 2004) (supreme court held trial court determines credit, subject to DOC modification; applies to community corrections)