William J. Woodford v. State of Indiana
2016 Ind. App. LEXIS 284
| Ind. Ct. App. | 2016Background
- William J. Woodford was convicted in 2000 (Dealing in Cocaine, Class A; Possession, Class D) and sentenced as a habitual offender to an aggregate 70-year DOC term; convictions were affirmed on direct and post-conviction review.
- Woodford filed multiple petitions to modify his sentence (2009, two in 2014) which were denied; on September 28, 2015 he filed a new petition seeking suspension/reduction to 40 years and placement in community corrections.
- The trial court ordered a DOC conduct report, held a hearing, then declined to reduce/suspend the sentence but ordered the final 12 years to be served in community corrections (in-home detention) subject to program acceptance.
- The State argued the court lacked authority to hear Woodford’s 2015 petition without prosecutor consent, because Woodford had filed prior petitions before the statutory change.
- The Court of Appeals held the 2015 amendments to the sentence-modification statute applied to Woodford and that the prosecutor’s consent was not required for his first petition under the revised law; but the court remanded for the trial court to reconsider the petition under the 2015 statute because it was unclear whether the trial court relied on the revised statute when modifying placement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court had authority to hear Woodford’s 2015 petition without prosecutor consent | State: prior petitions (pre-amendment) count toward statutory two-petition limit, so prosecutor consent required | Woodford: 2015 statute applies prospectively to grant two petitions without consent to those sentenced before July 1, 2014; his 2015 filing was his first under new scheme | Court: Prosecutor consent not required; trial court had authority to hear the 2015 petition |
| Whether trial court abused discretion by modifying placement but not reducing sentence | Woodford: exemplary conduct, education, age justify full relief (reduce/suspend and community placement) | State: (chose not to cross-appeal; argued trial court lacked authority) | Court: Remanded — unclear if trial court applied the 2015 statute; ordered new hearing to consider reduction/suspension under I.C. § 35-38-1-17 (Supp. 2015) |
Key Cases Cited
- Woodford v. State, 752 N.E.2d 1278 (Ind. 2001) (direct appeal affirming Woodford’s convictions)
- Pelley v. State, 828 N.E.2d 915 (Ind. 2005) (statutes given prospective effect absent clear legislative intent)
- K.S. v. State, 849 N.E.2d 538 (Ind. 2006) (procedural errors often treated as nonjurisdictional; limits on post-judgment authority)
- Brown v. State, 947 N.E.2d 486 (Ind. Ct. App. 2011) (remedial statutes should be liberally construed to cure prior defects)
- Vazquez v. State, 37 N.E.3d 962 (Ind. Ct. App. 2015) (interpreting petition-frequency limits under the amended sentence-modification statute)