Indiana Supreme Court

Alberto Baiza Rodriguez, Appellant v. State of Indiana, Appellee.

August 7, 2019129 N.E.3d 789

Summary

The court held that the statutory amendments governing sentence modification did not displace the longstanding rule that a court may modify a sentence imposed under a fixed-term plea agreement only if the modified sentence would have been authorized by the agreement. Because Rodriguez's plea agreement required specific work-release terms and reserved no discretion to alter them, the trial court lacked authority to modify his sentence. The court therefore affirmed the denial of his modification petition.