EATON v. STATE (2025)

MEMORANDUM DECISION

[1] Riki Eaton shot his cousin, Jenny Boltinghouse, and dumped her body into the White River. The murder remained unsolved for four years until Eaton's sister told police that Eaton had confessed to the crime. Eaton was then convicted of murder and adjudicated as a habitual offender. He now challenges his resulting 66-year sentence on two grounds. He claims: (1) the court failed to consider his self-reported alcohol abuse as a mitigating factor; and (2) a discrepancy exists between the court's oral and written sentencing statements. We affirm.

Facts

[2] In February 2017, Eaton learned that Boltinghouse planned to tell police about some thefts in which Eaton was involved. Eaton then called Boltinghouse and confronted her about it. He also accused her and a friend of stealing some of his tools and threatened to “take [them] both to the levee”—a spot along the White River that Eaton and his friends regularly visited—“and kill [them].” Tr. Vol. II, p. 73.

[3] Later that night, Eaton and his girlfriend drove to pick up Boltinghouse. Though the record is unclear as to what Eaton told Boltinghouse, Eaton told his girlfriend that Boltinghouse and her ex-boyfriend had gotten into a dispute and that they were meeting up with that ex-boyfriend at the levee to “figure out whatever disagreement they were having.” Tr. Vol. III, p. 34. The three—Eaton, his girlfriend, and Boltinghouse—drove to the White River. There, they parked and walked toward the riverbank. As Eaton's girlfriend walked ahead by herself, she heard multiple gunshots behind her. She looked back and saw Boltinghouse on the ground and Eaton with a gun in his hands.

[4] Eaton then orchestrated an elaborate cover-up. He picked up three friends and forced them to help him, wielding a gun and threatening to kill those who refused. When the group returned to Boltinghouse's body on the riverbank, they found her lying on the ground with multiple gunshot wounds to the head. They dragged her body down the bank and into the river, then collected shell casings from the ground. Eaton threatened to kill anyone who spoke to authorities, warning that “if anyone [said] anything ․ they're next.” Id. at 80.

[5] The murder remained unsolved for years. Then, in 2021, Eaton's sister told police that Eaton had confessed to killing Boltinghouse. Eaton was charged with murder and found guilty after a bench trial. He subsequently pleaded guilty to being a habitual offender based on two prior unrelated felonies.

[6] At sentencing, the trial court found several aggravating factors: Eaton's “total disregard for [Boltinghouse's] humanity” by disposing of her body in the river, his criminal history (beyond the felonies that constituted his habitual offender finding), and his attempts to conceal the murder by threatening witnesses. Id. at 164. The court also recognized a few mitigating circumstances with limited significance: Eaton's learning disabilities, his incarceration at a young age, his vague apology for his involvement with Boltinghouse's death (while still maintaining his innocence), and his relationship with one of his children. After considering these circumstances, the court sentenced Eaton to 60 years for murder and imposed an additional 6 years for his habitual offender status.

Discussion and Decision

[7] Eaton appeals his sentence on two grounds. First, he argues the trial court abused its discretion by failing to consider his self-reported history of alcohol abuse as a mitigating factor during sentencing. Second, he contends a discrepancy exists between the trial court's oral sentencing pronouncement and its written sentencing documentation. Unpersuaded by either argument, we affirm.

I. Mitigating Factors

[8] Sentencing decisions “rest within the sound discretion of the trial court and are reviewed on appeal only for an abuse of discretion.” Anglemyer v. State, 868 N.E.2d 482, 490 (Ind. 2007), clarified on reh'g, 875 N.E.2d 218 (Ind. 2007). One way a trial court abuses its discretion is by omitting from its sentencing statement a mitigating factor that is both significant and clearly supported by the record. Id. at 490-91. Eaton argues that the trial court did just that when it failed to recognize his history of alcohol abuse as a mitigating factor, despite noting several other mitigating circumstances. We disagree.

[9] First, the evidence Eaton presented in support of this mitigating factor was entirely based on his own self-serving statements. Eaton testified that he had a “big problem” with alcohol around the time of the murder. Tr. Vol. III, p. 158. His presentence investigation report notes the same self-reported alcohol abuse and his account that he was intoxicated the night of the murder. A trial court is not required to accept a defendant's arguments as to what constitutes a mitigating factor. Mehringer v. State, 152 N.E.3d 667, 673 (Ind. Ct. App. 2020). Nor is a court “obligated to explain why” it did not find a proffered circumstance to constitute a mitigating factor. Anglemyer, 868 N.E.2d. at 493.

[10] Second, the record suggests that Eaton's alcohol use had little to do with his crime. Though Eaton had been drinking the night of the murder, he was merely “buzzed but not drunk or belligerent.” Tr. Vol. III, p. 32. His actions that night—making threats to Boltinghouse, picking her up hours later, executing the murder, and coordinating a cover-up with multiple accomplices—demonstrate calculated planning inconsistent with alcohol-induced diminished capacity. See Healey v. State, 969 N.E.2d 607, 617 (Ind. Ct. App. 2012) (finding no abuse of discretion in refusing to recognize substance abuse as mitigator where defendant failed to show offense was caused by his substance use).

[11] For these reasons, we cannot say that the trial court abused its discretion by failing to recognize Eaton's alleged alcohol abuse as a mitigating factor. Even if the trial court had erred, we would remand only if we could not “say with confidence that the trial court would have imposed the same sentence had it properly considered” the alleged mitigating factor. Anglemyer, 868 N.E.2d at 491. Given the various aggravating circumstances identified by the trial court—including Eaton's criminal history, the grave nature of the offense, and his attempts to conceal it—we can say with confidence that consideration of any alcohol-use disorder would not have led to the imposition of a different sentence. See Ackerman v. State, 51 N.E.3d 171, 194 (Ind. 2016) (finding no remand necessary where multiple aggravating circumstances existed, including the grave nature of the crime and the defendant's criminal history).

[12] We find no reversible error in the trial court's failure to recognize Eaton's claimed alcohol abuse as a mitigating factor.

II. Sentencing Statements

[13] Eaton claims that a discrepancy exists between the trial court's oral and written sentencing statements, and that such discrepancy creates confusion. We disagree, finding the documentation clearly conveys Eaton's sentence.

[14] At sentencing, the trial court orally stated that Eaton was sentenced for “the charge of murder to 60 years ․ enhanced by an additional 6 years based on the two [prior] convictions.” Tr. Vol. III, p. 166. The written sentencing order reflects the same, though worded differently. It lists Eaton's sentence for murder as 66 years, then notes that such sentence was “enhanced by 6 years for [the] Habitual Offender Sentence Enhancement for a total of 66 years.” App. Vol. II, p. 28. It reads, in pertinent part:

Id.

[15] Similarly, the abstract of judgment lists Eaton's sentence for murder as 66 years and explains that this sentence “also included” the 6-year enhancement. Id. at 30. It reads, in pertinent part:

Id.

[16] These documents make clear that Eaton was sentenced to a total of 66 years—a figure that already included the 6-year habitual offender enhancement. We find no ambiguity or risk of misinterpreting a different sentence.

[17] To the extent that Eaton argues the habitual offender enhancement and murder sentence should be listed separately, we disagree. “A habitual offender finding does not constitute a separate crime nor result in a separate sentence;” instead, it enhances the sentence for the underlying felony. Greer v. State, 680 N.E.2d 526, 527 (Ind. 1997). Therefore, the incorporation of the enhancement into the murder sentence for a total of 66 years properly reflects this principle. See Davis v. State, 935 N.E.2d 1215, 1218 (remanding to correct trial court's erroneous imposition of habitual offender enhancement as separate sentence). Remand is not necessary.¹

Conclusion

[18] We find no error in the trial court's failure to recognize Eaton's self-reported alcohol abuse as a mitigating factor. We also conclude that the sentencing documentation makes clear that Eaton was sentenced to 60 years for murder plus 6 years for the habitual offender enhancement, for a total of 66 years. We affirm.

affirmed

FOOTNOTES

1.   Though we find no confusion in the documentation here, we note that trial courts could ensure clarity by listing each component of an enhanced sentence—the sentence on the underlying felony, the enhancement time, and the total combined sentence—in the section of the documents reserved for comments.

Weissmann, Judge.

May, J., and Scheele, J., concur.