Eiler v. State
2010 Ind. App. LEXIS 2450
| Ind. Ct. App. | 2010Background
- Eiler owned a barn in Shelby County used for recreation including drug use; police recovered about eight grams of cocaine from the barn on Oct. 29, 2008.
- On Oct. 31, 2008, the State charged Eiler with multiple offenses including counts for dealing cocaine and marijuana at various degrees.
- On March 19, 2010, Eiler pled guilty to Count IX, dealing cocaine as a class A felony, under a plea agreement capping executed time at 22 years and dismissing the other counts.
- At the May 13, 2010 sentencing, Eiler testified about six months of cocaine use prior to arrest and his addiction; he admitted limited, non-profitable cocaine sales to a few individuals.
- The trial court sentenced Eiler to 22 years in the DOC with four years suspended to probation and made a non-binding recommendation for minimum-security/work release placement.
- The Court of Appeals reversed and remanded, concluding the sentencing order failed to provide reasonable reasons; a modified disposition was issued to 22 years with 10 years suspended, in line with the court’s preference for minimum-security/work release.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentencing statement was adequate | Eiler argues the court failed to provide detailed reasons for the sentence. | State contends no detailed aggravators/mitigators are required under the current scheme. | Abuse of discretion for inadequate sentencing statement; remand or revise. |
| Whether the sentence is inappropriate given the offense and offender | Eiler claims factors like age, minimal criminal history, and lack of profit mitigate severity. | State contends the sentence within the plea cap is appropriate given the offense. | Sentence modified to 22 years with 10 years suspended; remanded for resentencing consistent with opinion. |
Key Cases Cited
- Anglemyer v. State, 868 N.E.2d 482 (Ind.2007) (requires a detailed sentencing statement; helps prevent arbitrary sentences)
- Cardwell v. State, 895 N.E.2d 1219 (Ind.2008) (discretionary sentencing with need for reasons; supports remand for proper statement)
- Windhorst v. State, 868 N.E.2d 504 (Ind.2007) (remand or modification when sentencing errors occur)
- Williams v. State, 827 N.E.2d 1127 (Ind.2005) (directs appellate review of sentences under 7(B))
- Brown v. State, 783 N.E.2d 1121 (Ind.2003) (proper use of sentencing records and authority to remand)
- Mendoza v. State, 869 N.E.2d 546 (Ind.Ct.App.2007) (aggrieved by inadequate sentencing statements; remand considered)
- Nasser v. State, 727 N.E.2d 1105 (Ind.Ct.App.2000) (record completeness and waiver concerns in sentencing arguments)