Ronnie Jamel Rice v. State of Indiana
2014 Ind. LEXIS 316
Ind.2014Background
- Rice pled guilty to murder, murder in the perpetration of a robbery, and robbery and was sentenced to life without parole.
- Rice appealed arguing the original and revised sentencing orders relied on non-statutory aggravators.
- This Court remanded for a revised sentencing order to clarify reliance on non-capital aggravators.
- The trial court issued a revised order (March 5, 2013) with one statutory aggravator and three mitigating factors, plus evaluative language about balancing factors.
- Indiana law since 2005 allows non-exhaustive aggravators; after Harrison and Anglemyer, sentencing must be detailed but not reveal impermissible non-statutory aggravators.
- This Court reviews for abuse of discretion and upholds sentences that are not improper in light of the record and balancing of factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the revised order properly balanced aggravators and mitigators | Rice argues the order uses non-statutory aggravators and is mitigation-neutralizing. | State contends the challenged language explains balancing and is not an improper aggravator. | No abuse; order properly explains balancing and weight of factors. |
| Whether the sole aggravator and mitigating factors were properly identified and weighed | Rice claims factors are non-statutory and improperly weight inconsistencies. | State maintains the factors are legitimate and weighed against the sole statutory aggravator. | Correct; findings support the balancing against the sole aggravator. |
| Whether the sentence is appropriate under appellate review standards | Rice seeks revision to a term of years if not remanded for new sentencing. | State argues Sentence is appropriate and appellate Rule 7(B) does not mandate modification. | Sentence affirmed; no revision warranted. |
Key Cases Cited
- Harrison v. State, 644 N.E.2d 1243 (Ind. 1995) (requires detailed sentencing findings to support aggravating/mitigating reasons)
- Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (requires reasonably detailed recitation of reasons for balancing factors)
- Pittman v. State, 885 N.E.2d 1246 (Ind. 2008) (trial court must follow balancing standards for death penalty / life without parole)
- Conley v. State, 972 N.E.2d 864 (Ind. 2012) (illustrates length of permissible sentencing orders in Indiana)