James Ricketts v. State of Indiana (mem. dec.), 65A01-1603-CR-676

In June 2014, James Ricketts pled guilty to Class C felony nonsupport of a dependent child; the trial court imposed a four-year sentence and suspended it to probation under a plea agreement.
Probation conditions included reporting, drug testing, maintaining employment, and paying $200/month toward child-support arrears (Ricketts acknowledged ~$35,300 arrears).
July 2014 drug screen was positive for methamphetamine; Ricketts admitted recent use and was referred for substance-abuse counseling but did not follow through.
Ricketts missed scheduled probation office visits in August and September 2014 and refused a November 2014 drug test after being warned; he said he would rather “sit a year” than comply.
The State filed a petition to revoke probation; Ricketts was arrested November 9, 2015, admitted the violations at an evidentiary hearing, and at disposition the court revoked probation and ordered him to serve the balance of the four-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by revoking probation and ordering execution of the full suspended sentence	State: Ricketts committed multiple probation violations (missed reporting, positive and refused drug tests, failure to pay child support), supporting revocation and execution of the suspended sentence	Ricketts: The trial court’s decision to order him to serve the remaining sentence was an abuse of discretion (argued against full execution)	Court affirmed: multiple admissions of violations gave the trial court discretion to revoke probation and order execution of the suspended sentence

Prewitt v. State, 878 N.E.2d 184 (Ind. 2007) (probation is discretionary and courts may set conditions and revoke for violations)
Pierce v. State, 44 N.E.3d 752 (Ind. Ct. App. 2015) (a single probation violation can support revocation)