Michael Moore v. State of Indiana (mem. dec.), 49A02-1610-CR-2371

Michael Moore pled guilty to three counts of Level 4 felony burglary (three separate incidents in Aug–Sep 2015) and admitted habitual-offender status; pleas were accepted July 28, 2016.
Two burglaries were linked to Moore by fingerprints; he admitted participation in the third.
At sentencing the court heard that Moore suffers from schizophrenia and that his criminal behavior correlated with noncompliance with prescribed medication.
The trial court imposed an aggregate 32-year sentence: six years executed (minimum required because of habitual-offender status), three years in community corrections, and the remainder suspended to probation; probation required taking prescribed medications.
On appeal Moore argued the court abused its discretion by not finding his guilty plea to be a significant mitigating factor.
The trial court questioned the sincerity of Moore’s acceptance of responsibility, noting he blamed co-defendants and drug use, and found the plea insufficiently mitigating given the strength of the evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Moore)	Held
Whether the trial court abused its discretion by failing to find Moore’s guilty plea a significant mitigating factor	The plea need not be given significant weight where the record shows lack of sincere acceptance of responsibility and strong evidence of guilt	Moore argued his guilty plea deserved significant mitigating weight	Court affirmed: no abuse of discretion — plea not significantly mitigating because Moore blamed others/drugs and evidence (fingerprints/admission) made the plea largely pragmatic

Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (standards for reviewing sentencing statements and abuse-of-discretion review)
Fugate v. State, 608 N.E.2d 1370 (Ind. 1993) (trial court not required to find mitigating factors)
Graham v. State, 535 N.E.2d 1152 (Ind. 1989) (discussing mitigating-factor discretion)
Hammons v. State, 493 N.E.2d 1250 (Ind. 1986) (trial court not required to explain rejection of proffered mitigating factors)
McElroy v. State, 865 N.E.2d 584 (Ind. 2007) (guilty plea may not be significantly mitigating where plea confers substantial benefit or absence of true acceptance of responsibility)
Stout v. State, 834 N.E.2d 707 (Ind. Ct. App. 2005) (trial court best positioned to judge sincerity of remorse)
Wells v. State, 836 N.E.2d 475 (Ind. Ct. App. 2005) (guilty plea not significantly mitigating when plea is pragmatic given strong evidence)
Sensback v. State, 720 N.E.2d 1160 (Ind. 1999) (same principle that strong evidence can render plea pragmatic)