William J. Woodford v. State of Indiana (mem. dec.)
20A03-1612-CR-2812
| Ind. Ct. App. | Jun 20, 2017Background
- In 2000 William J. Woodford was convicted of dealing in cocaine (Class A) and possession (Class D) and adjudicated a habitual offender; the trial court imposed an aggregate 70-year sentence. The convictions and subsequent post-conviction challenges were previously affirmed.
- Woodford repeatedly petitioned for sentence modification; in January 2016 the trial court declined to reduce the sentence but ordered the final 12 years be served on home detention through county community corrections with frequent drug testing.
- This court in Woodford v. State, 58 N.E.3d 282 (Ind. Ct. App. 2016), remanded because it was unclear whether the trial court applied the amended 2015 modification statute (Ind. Code § 35-38-1-17) and instructed a new hearing under that statute.
- At the November 17, 2016 remand hearing Woodford (pro se) sought suspension or reduction of his 70-year sentence by 30 years (to 40 years) and placement in a community corrections work-release program, citing age, educational accomplishments, and 16+ years without conduct violations.
- The trial court reaffirmed its prior decision to modify placement only (final 12 years to home detention with weekly/frequent drug testing), explaining concerns about Woodford’s historical serious drug addiction and preferring a program with more frequent testing than probation/work-release would provide.
- The Court of Appeals reviewed the denial for abuse of discretion and affirmed, finding the trial court gave stated reasons on the record and acted within its discretion.
Issues
| Issue | Woodford's Argument | State/Trial Court's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by denying Woodford’s request to reduce or suspend his sentence (to 40 years) and instead ordering the final 12 years served on home detention | Woodford argued he is rehabilitated (age, education, clean conduct record) and that prison resources should be conserved; he sought full relief to suspend/reduce sentence and place him on community corrections work release | The State opposed reducing the sentence; the trial court emphasized Woodford’s serious past drug addiction and chose home detention for more frequent drug testing and monitoring | Affirmed. No abuse of discretion. The court reasonably declined to reduce/suspend and explained its reasons on the record |
Key Cases Cited
- Woodford v. State, 752 N.E.2d 1278 (Ind. 2001) (affirming Woodford’s convictions)
- Woodford v. State, 58 N.E.3d 282 (Ind. Ct. App. 2016) (remanding to apply amended sentence modification statute)
- Carr v. State, 33 N.E.3d 358 (Ind. Ct. App. 2015) (abuse-of-discretion standard for sentence-modification rulings)
- Hobbs v. State, 26 N.E.3d 983 (Ind. Ct. App. 2015) (same standard for reviewing modification decisions)