Williams v. State
2010 Ind. App. LEXIS 2289
| Ind. Ct. App. | 2010Background
- Williams pled guilty to operating a vehicle while intoxicated as a class A misdemeanor and admitted habitual substance offender status, receiving four years in HOCCS home detention with 205 days suspended to probation.
- HOCCS monitored Williams; a February 1, 2010 urinalysis tested positive for marijuana, leading HOCCS to file a violation notice on February 2, 2010 and an addendum on February 10, 2010.
- A March 19, 2010 revocation hearing addressed the positive test and Williams's alleged field-tracking violations (device tampering and absence during a February 5, 2010 field visit).
- Two State exhibits were admitted: (1) Urinalysis Report (February 1, 2010) and (2) Daily Summary from BI Inc. showing monitoring device disconnections in February 2010.
- Williams objected to both exhibits, challenging reliability and foundation; the court overruled the objections.
- The trial court revoked Williams’s in-home detention, ordering him to serve the remainder of the executed sentence in jail, while not altering the suspended probation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by admitting the Urinalysis Report and Daily Summary | Williams argues the documents lacked trustworthiness and proper foundation | State contends the evidence is trustworthy and admissible under probation-revocation standards | No abuse of discretion; exhibits properly admitted, and any error harmless |
Key Cases Cited
- Reyes v. State, 868 N.E.2d 438 (Ind. 2007) (adopts substantial trustworthiness test for hearsay in probation revocation)
- Holmes v. State, 923 N.E.2d 479 (Ind. Ct. App. 2010) (probation revocation evidence receipt upheld)
- Figures v. State, 920 N.E.2d 267 (Ind. Ct. App. 2010) (one violation can support revocation; evidence admissible)
- Brooks v. State, 692 N.E.2d 951 (Ind. Ct. App. 1998) (revocation standard mirrors probation revocation procedure)
- J.J.C. v. State, 792 N.E.2d 85 (Ind. Ct. App. 2003) (monitoring-entries lack of explanation may failure to prove violation)