ROBINSON v. STATE (2025)

MEMORANDUM DECISION

Case Summary

[1] Troy M. Robinson, Jr.’s probation was revoked and the trial court ordered him to serve a portion of his previously suspended sentence, with four days’ credit for time served. Robinson appeals, raising one issue: did the trial court erroneously allocate his credit time? We conclude this appeal is moot because Robinson has served his time and therefore dismiss.

Facts and Procedural History

[2] Robinson pleaded guilty in Wabash County to Level 6 felony counterfeiting in case number 85C01-1910-F6-1494 (“Case 1494”) and in December 2020, was sentenced to one and one-half years’ incarceration, with one year suspended to probation. He began serving his probation on August 25, 2023.¹

[3] On June 15, 2024, Robinson was arrested in Grant County and later charged with several crimes. On June 21, Wabash County filed a petition to revoke Robinson's probation in Case 1494 because of these June charges and issued a warrant for his arrest. Robinson remained in the Grant County Jail from June 15 to August 10. On August 14, Robinson was served with the Wabash County arrest warrant. He posted bond and was released on August 15.

[4] On August 27, Robinson was charged with several more crimes in Grant County. He was arrested on these new charges on September 4 and incarcerated in the Grant County Jail.

[5] Also on September 4, Wabash County filed a second petition to revoke Robinson's probation in Case 1494 in part because of the August charges and issued an arrest warrant stating, “Hold Without Bond.” Appellant's App. Vol. 2 at 137. Robinson was served with the Wabash County warrant on November 14 while still in the custody of the Grant County Jail.

[6] On December 12, Robinson was transported from the Grant County Jail to Wabash County for a hearing in Case 1494. Robinson admitted to violating his probation. The court revoked his probation and ordered him to serve ten months of his previously suspended sentence in jail. At the court's request, the probation department reviewed Robinson's credit time and filed a notice to the court stating Robinson was incarcerated in the Grant County Jail from June 15, 2024, to August 10, 2024 (57 actual days), and again from September 4, 2024, to December 11, 2024 (99 actual days), for a total of 312 actual and good-time-credit days. The notice also advised Robinson was incarcerated in the Wabash County Jail from August 14, 2024, to August 15, 2024 (two days), for a total of four actual and good-time-credit days.

[7] The State responded to the notice and recommended Robinson receive only the four days’ credit for time served in Wabash County as the remainder of the days were attributable to the Grant County cases. Robinson also responded and requested the court “allot all current credit time” to Case 1494, “award [him] the applicable credit time in this matter of Three Hundred (300) days [and] enter judgment as time served[.]” Id. at 161. The court gave Robinson credit for only the four days attributable to his time in the Wabash County Jail.²

Robinson has served his sanction, and no relief can be granted to him.

[8] Robinson contends the trial court erred in allocating only four days credit time toward his sanction for violating probation. He asks that we “clarify the allocation of credit time in consecutive sentences between multiple jurisdictions.” Appellant's Br. at 12. The State argues Robinson's appeal is moot, noting he has completed his ten-month sanction. We agree with the State.

[9] “A case becomes moot when the controversy at issue has been ended, settled, or otherwise disposed of so that the court can give the parties no effective relief.” Spells v. State, 225 N.E.3d 767, 777 (Ind. 2024) (internal quotation omitted); see Bell v. State, 1 N.E.3d 190, 192 (Ind. Ct. App. 2013) (“[W]hen we are unable to provide effective relief upon an issue, the issue is deemed moot, and we will not reverse the trial court's determination where absolutely no change in the status quo will result.” (quotation omitted)).

[10] Robinson began serving his sanction on December 12, 2024. Along with its brief, the State filed an appendix containing a document from the Wabash County Sheriff showing Robinson was released on May 19, 2025. See Appellee's App. Vol. 2 at 2. Once a “sentence has been served, the issue of the validity of the sentence is rendered moot.” Lee v. State, 816 N.E.2d 35, 40 n.2 (Ind. 2004) (quoting Irwin v. State, 744 N.E.2d 565, 568 (Ind. Ct. App. 2001)). Even if we were to decide Robinson was entitled to additional credit time, our decision would not result in a change in the status quo because he has already served his sentence.³ As such, Robinson's appeal is moot.

[11] Generally, moot cases are dismissed. See I.J. v. State, 178 N.E.3d 798, 799 (Ind. 2022) (per curiam). An exception may be made when the case involves a question of “great public importance that is likely to recur.” Id. Here, the State raised mootness in its Appellee's Brief. Robinson did not file a reply brief making a public importance exception argument, and we decline to apply the exception here to address the merits of Robinson's claim.⁴

Conclusion

[12] Robinson's appeal is moot because even if Robinson were entitled to additional credit time, it would provide him no relief.

[13] Dismissed.

FOOTNOTES

1.   Robinson's sentence was ordered to be served consecutively to a sentence in another case and his probation began after that sentence was completed.

2.   Robinson filed a Motion to Correct Error regarding the credit time allocation. After a hearing, the trial court denied the motion. Robinson timely filed a Notice of Appeal but filed it in the Wabash Circuit Court instead of with the Clerk of the Indiana Supreme Court, Court of Appeals, and Tax Court. See Ind. Appellate Rule 9(A). Robinson was granted permission to file a belated notice of appeal.

3.   As the State points out, if we were to address this appeal on the merits and decide additional credit time should have been allocated toward Robinson's sanction, it would prejudice him because “not only will [he] be unable to enjoy it in this case, but it would be unavailable to be applied to his still-pending Grant County cases should he be convicted there.” Appellee's Br. at 7.

4.   Because Robinson did not file a reply brief, he also did not challenge the State's assertion that he has served his sanction.

Kenworthy, Judge.

Foley, J., and Scheele, J., concur.