Dominique Castillo v. State of Indiana
2017 Ind. App. LEXIS 5
| Ind. Ct. App. | 2017Background
- Defendant Dominique Castillo pleaded guilty to Level 5 sexual misconduct with a minor and received a 4-year sentence with 2.5 years suspended to probation and 1.5 years executed.
- Probation conditions prohibited contact with persons under 18 without probation officer authorization and prohibited living within one mile of the victim.
- After release, Castillo lived with a 17‑year‑old girlfriend and her family (including a 14‑year‑old), in violation of his probation terms; he admitted to the violation at the revocation hearing.
- The trial court found a probation violation and ordered execution of the entire 2.5‑year suspended portion of the sentence.
- Castillo appealed, arguing (1) the court violated due process by failing to state specific reasons for imposing full execution of the suspended sentence, and (2) the absence of an explanatory statement raises the possibility the court relied on improper evidence or factors.
- The Court of Appeals affirmed, holding no due process requirement for a detailed statement of reasons for the sanction and that the court did not abuse its discretion.
Issues
| Issue | State's Argument | Castillo's Argument | Held |
|---|---|---|---|
| Whether due process requires the trial court to state specific reasons for ordering execution of the previously suspended sentence after revocation | No — Medicus and related authority require a written statement for revocation itself but not a specific statement explaining the chosen sanction; no rule requires listing rejected alternatives | Yes — due process required a statement of specific reasons for imposing full execution instead of alternative sanctions | Court: No — trial court satisfied due process for revocation and was not required to give specific reasons for the sanction; affirmed |
| Whether the court may have considered improper evidence/factors because it gave no specific reasons for the sanction | No — record shows the court heard testimony, relied on Castillo’s admissions and found a blatant violation; nothing indicates improper factors were considered | Yes — absence of a rationale permits speculation that the court considered improper factors (e.g., officer opinion, nature of underlying offense, family disputes) | Court: No — speculation insufficient; facts show appropriate basis for sanction and no abuse of discretion |
Key Cases Cited
- Medicus v. State, 664 N.E.2d 1163 (Ind. 1996) (requires written statement of reasons for probation revocation under Morrissey)
- Black v. Romano, 471 U.S. 606 (1985) (Morrissey does not require explicit statement that alternatives to incarceration were considered and rejected)
- Morrissey v. Brewer, 408 U.S. 471 (1972) (minimum due process protections for parole revocation proceedings)
- Prewitt v. State, 878 N.E.2d 184 (Ind. 2007) (probation is discretionary; revocation reviewed for abuse of discretion)
- Puckett v. State, 956 N.E.2d 1182 (Ind. Ct. App. 2011) (examples of revocation where improper factors influenced sanction decision)