MCADAMS v. STATE (2025)

MEMORANDUM DECISION

Case Summary

[1] Patrick L. McAdams appeals the trial court's revocation of a portion of his previously suspended sentence following multiple probation violations, claiming that it is an abuse of discretion. We disagree and therefore affirm.

Facts and Procedural History

[2] In March 2018, the State charged McAdams with possession of methamphetamine, as a Level 6 felony.¹ In August 2019, McAdams pleaded guilty as charged in exchange for a sentence of two years, all suspended to probation. McAdams’ probation commenced in October 2024.

[3] In February 2025, the State filed an amended petition for revocation of probation, which alleged that McAdams had violated the conditions of his probation as follows: (1) being charged with nonsupport of a dependent child in Jennings County; (2) failing to report to the probation department “to start his supervision”; (3) submitting a urine sample that tested positive for methamphetamine, amphetamine, and THC in October 2024; (4) failing to report for scheduled drug screens in October, November, and December 2024 and January and February 2025; (5) failing “to call the drug screen hotline” over 100 times; (6) failing “to report for a scheduled office visit” in November and December 2024; and (7) not providing “any proof of progress towards his 20 hours of Community Service Work.” Appellant's App. Vol. 2 at 76-77.

[4] The trial court held a fact-finding hearing in February 2025. At the beginning of the hearing, defense counsel stated,

Your Honor, there [are] multiple parts of the petition that my client admits to, specifically, the ones since he was supposed to start probation when we were here back on October 3rd, 2024, regarding failing to report for scheduled drug screens, no-showed on multiple dates, and not making progress towards the 20 hours community service work. So those he would admit to.

Tr. Vol. 2 at 4. Counsel then questioned McAdams, who admitted that he had failed to report for multiple drug screens and scheduled visits with his probation officer and further admitted that he had submitted a urine sample that tested positive for illegal substances. Id. at 6-7. He also acknowledged a pending child support case in Jennings County. Id. at 11-12. McAdams told the court that he was currently employed as a painter, that he had “a bed scheduled” in a recovery center in Indianapolis that very day, and that he “would not mess up again.” Id. at 10.

[5] The State called Curtis Keppel, McAdams’ probation officer, as a witness. Keppel testified that he had a single face-to-face meeting with McAdams and that after McAdams submitted the positive urine sample, he “quit engaging in the Drug Hotline, quit showing up, and quit altogether[.]” Id. at 14. Keppel further testified that he had arranged for McAdams to be treated in the same Indianapolis recovery center in October 2024; that arrangement apparently fell through because McAdams failed to report to him. Id. at 16.

[6] At the conclusion of the hearing, the trial court remarked,

I am going to accept Mr. McAdams’ admission to being in violation of the conditions of his probation as was laid out earlier, and based on that admission find him to be in violation.

Considering his lack of engagement and participation, I also don't think he is a good candidate for future supervision. I am going to order that 500 days of his suspended sentence are revoked to the Decatur County Jail. Probation terminates being unsuccessful.

Id. at 17. This appeal ensued.

Discussion and Decision

[7] McAdams argues that the trial court's sanction for his admitted probation violations is too harsh and that he should be placed back on probation. The purposes of probation are “rehabilitating the probationer and protecting the public.” Weida v. State, 94 N.E.3d 682, 685 (Ind. 2018). Probation “is ‘a matter of grace and a conditional liberty that is a favor, not a right.’ ” State v. Vanderkolk, 32 N.E.3d 775, 777 (Ind. 2015) (quoting Cox v. State, 706 N.E.2d 547, 549 (Ind. 1999)). We review probation violation sanctions for an abuse of discretion. Heaton v. State, 984 N.E.2d 614, 616 (Ind. 2013). “An abuse of discretion occurs where the decision is clearly against the logic and effect of the facts and circumstances, or when the trial court misinterprets the law.” Id. (citations omitted).

[8] Probation revocation is a two-step process, in which the trial court first makes a factual determination as to whether the probationer violated the terms of his probation. Woods v. State, 892 N.E.2d 637, 640 (Ind. 2008). If a violation is found, the court may (1) continue the probation, with or without modifying or enlarging the conditions; (2) extend the probationary period for up to one year; or (3) order execution of all or part of the sentence that was suspended at the initial sentencing hearing. Ind. Code § 35-38-2-3(h). A single violation of a condition of probation is sufficient to permit the trial court to revoke probation. Pierce v. State, 44 N.E.3d 752, 755 (Ind. Ct. App. 2015).

[9] Here, McAdams admitted to violating multiple conditions of probation on multiple occasions. He characterizes these violations as “technical in nature” and argues that they “were counterbalanced by [his] recognition of his need for additional help and efforts to obtain that help.” Appellant's Br. at 11. We disagree. McAdams’ positive urine screen—the only screen he ever submitted to—indicated that he possessed and used illegal substances, which posed a potential danger to the public. He went radio silent on his probation officer, failed to comply with his community service obligation, and took no meaningful steps toward rehabilitation until he faced the prospect of losing his conditional liberty. Under these circumstances, we cannot say that the trial court abused its discretion in ordering McAdams to serve 500 days of his suspended sentence.

[10] Affirmed.

FOOTNOTES

1.   Ind. Code § 35-48-4-6.1(a).

Bailey, Judge.

Brown, J., and Weissmann, J., concur.