Harry Hobbs v. State of Indiana, 2017 Ind. App. LEXIS 64

In 1993 Hobbs was charged with multiple sexual and burglary offenses; a jury convicted him on four counts (three class A felonies, one class B felony).
In 1994 the trial court sentenced Hobbs to 50 years (Counts 1 and 4), 30 years (Count 2), and 20 years (Count 3), arranged to produce an aggregate 120-year term.
Hobbs challenged his convictions and sentence on direct appeal; this Court affirmed.
In 2015 Hobbs filed a motion to correct erroneous sentence arguing that post‑1994 statutory amendments reduced presumptive class A felony terms and capped aggregate consecutive sentences for a single episode of criminal conduct. The trial court denied relief.
On appeal this Court found Hobbs’s 50-year individual sentences exceeded statutory maxima and remanded for correction to 45 years each; the Court did not authorize full resentencing or reach the episode‑of‑criminal‑conduct cap.
On remand the trial court reduced the 50‑year sentences to 45 years, imposed 15 years on two other counts, and reconfigured the sentences to again total 120 years; Hobbs appealed the remand sentencing arrangement.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hobbs)	Held
Whether the corrected sentence on remand violates statutory limits because the offenses were a single episode of criminal conduct and cap aggregate consecutive sentences	The appeal is limited to the narrow error remanded; Hobbs cannot raise episode‑of‑criminal‑conduct claim via a motion to correct sentence	Hobbs argues his offenses were a single episode so the aggregate sentence must be reduced under the statutory cap	Court held Hobbs cannot raise that claim in this context; remand corrected the facial sentencing error only and trial court did not abuse discretion

Wilson v. State, 5 N.E.3d 759 (2014) (remedy on remand may rearrange individual sentences to effect a lawful aggregate sentence)
Robinson v. State, 805 N.E.2d 783 (2004) (statutory motion to correct sentence is an alternate, narrowly confined remedy for facial sentencing errors)
Woodcox v. State, 30 N.E.3d 748 (2015) (appellate standard for reviewing motions to correct erroneous sentence is abuse of discretion)
Davis v. State, 978 N.E.2d 470 (2012) (episode‑of‑criminal‑conduct challenges require factual inquiry beyond the face of the judgment and are not proper in a motion to correct sentence)
Lane v. State, 727 N.E.2d 454 (2000) (distinguishable as a direct‑appeal resentencing context)
Niece v. State, 456 N.E.2d 1081 (1983) (distinguishable as a direct appeal following correction proceedings)