Gregory A. Traylor v. State of Indiana (mem. dec.), 03A01-1709-CR-2017

On August 3, 2017 police executed a search warrant at Gregory Traylor’s home and seized one ounce of methamphetamine, 15 pounds of marijuana, 4 grams of heroin, large quantities of pseudoephedrine and methamphetamine manufacturing materials, at least 70 firearms, and numerous improvised explosive devices.
The State charged Traylor with multiple felonies: two Level 2 felonies (manufacturing and dealing methamphetamine) and three Level 5 felonies (possession of a narcotic, possession of a destructive device, dealing in marijuana).
A bench warrant issued and the trial court set bond at $5,000,000 or 10% cash.
Traylor moved for a bond reduction; at a hearing the court considered the statutory bail factors and denied the motion.
On appeal the Court of Appeals reviewed whether the $5,000,000 bond was excessive and an abuse of the trial court’s discretion, considering Traylor’s community ties, employment, lack of relevant criminal history, and severity of the charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying Traylor's motion to reduce $5,000,000 bail	Bond is justified by the seriousness of the offenses, potential penalties, public safety concerns, and evidence seized	$5,000,000 is excessive given Traylor’s long residency, family/community ties, employment history, assets, lack of relevant criminal history, and willingness to accept home detention	Court reversed: bond was excessive and appeared punitive; remanded to set a reasonable bond based on statutory factors

Lopez v. State, 985 N.E.2d 358 (Ind. Ct. App. 2013) (standard of appellate review for bail decisions)
Sneed v. State, 946 N.E.2d 1255 (Ind. Ct. App. 2011) (relation between initial bond setting and motions to reduce bail)
Collins v. State, 822 N.E.2d 214 (Ind. Ct. App. 2005) (deference to trial court findings and not reweighing evidence)
Mott v. State, 490 N.E.2d 1125 (Ind. Ct. App. 1986) (bail must be set to assure appearance, considering case circumstances)
Fry v. State, 990 N.E.2d 429 (Ind. 2013) (bail is not punishment; presumption of innocence)
Wertz v. State, 771 N.E.2d 680 (Ind. Ct. App. 2002) (affirming lower six-figure bail in serious drug case)
Custard v. State, 629 N.E.2d 1289 (Ind. Ct. App. 1994) (affirming significant but lower bail for serious drug charge)
Sherelis v. State, 452 N.E.2d 411 (Ind. Ct. App. 1983) (overturning excessive $1,000,000 bond where defendant had strong community ties)
Samm v. State, 893 N.E.2d 761 (Ind. Ct. App. 2008) (bail should be individualized and tailored to defendant)