Paul D. Woodcox v. State of Indiana
30 N.E.3d 748
| Ind. Ct. App. | 2015Background
- In 1989 a jury convicted Paul D. Woodcox of rape, attempted murder, criminal confinement, and found him a habitual offender; initial aggregate sentence was 150 years.
- The Indiana Supreme Court affirmed the rape (Class A) and confinement convictions but reversed attempted murder; after remand the trial court re-sentenced, yielding an aggregate 100-year sentence (tacking habitual-offender enhancement onto rape).
- In 2014 Woodcox filed a pro se Motion to Correct Erroneous Sentence under I.C. § 35-38-1-15, challenging the sentencing paperwork that listed rape as a Class B felony while imposing a 50-year term.
- The trial court summarily denied the motion; Woodcox appealed, arguing the judgment was facially erroneous because a 50-year sentence exceeds the statutory maximum for Class B rape.
- The Court of Appeals found the sentencing error was clerical (judgment misstates felony class) rather than substantive, and Woodcox actually was convicted of Class A rape as reflected in the prior supreme court opinion.
- Court affirmed the sentence (50 years + 30-year habitual enhancement) but remanded for nunc pro tunc correction of the judgment of conviction and abstract to reflect Class A felony rape.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in denying Motion to Correct Erroneous Sentence | The State: denial appropriate because the record and law do not show a facial sentencing error warranting correction under § 35-38-1-15 | Woodcox: sentencing judgment is facially erroneous because it labels rape a Class B felony yet imposes a 50-year term (exceeds Class B statutory max) | Denial affirmed; error was clerical (entry misstates felony class), not a correctable substantive sentencing error under § 35-38-1-15; court orders nunc pro tunc correction of judgment and abstract to show Class A rape |
Key Cases Cited
- Robinson v. State, 805 N.E.2d 783 (Ind. 2004) (motion under § 35-38-1-15 is limited to sentencing errors clear on the face of the judgment)
- Coppock v. State, 480 N.E.2d 941 (Ind. 1985) (clerical defects in the judgment may be treated as errors of form and corrected to conform to verdict)
- Pettiford v. State, 808 N.E.2d 134 (Ind. Ct. App. 2004) (defines when a sentence is defective on its face)
- Davis v. State, 978 N.E.2d 470 (Ind. Ct. App. 2012) (motion to correct sentence arises only from information on the formal judgment of conviction)
- Woodcox v. State, 591 N.E.2d 1019 (Ind. 1992) (supreme court opinion affirming Woodcox’s rape conviction as Class A felony)