William Bradley, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2025)

MEMORANDUM DECISION

Case Summary

[1] William Bradley brings this pro se appeal challenging the trial court's denial of his motion for credit time. Bradley claims that the Indiana Department of Correction (“DOC”) did not apply the credit time he earned toward his sentence. We disagree and affirm.

Issue

[2] Bradley raises one issue, which we restate as whether the trial court properly denied Bradley's motion for credit time.

Facts

[3] On March 8, 2023, Bradley was arrested and subsequently charged with five drug-related and firearms offenses.¹ On October 15, 2024, Bradley pleaded guilty to dealing in a narcotic drug, a Level 2 felony, and unlawful possession of a firearm by a serious violent felon, a Level 4 felony. In exchange, the State dismissed the remaining charges. That same day, the trial court sentenced Bradley to ten years on the Level 2 felony conviction and a concurrent term of six years on the Level 4 felony conviction. Six years of the sentence were to be served in the DOC, plus two years on work release and two years on house arrest. Bradley was incarcerated awaiting trial on these charges from March 8, 2023, through October 14, 2024—a total of 587 days. Accordingly, in its sentencing order and in the abstract of judgment, the trial court noted that Bradley earned 587 actual days of credit time, plus 196 days of good time credit.² The abstract also noted that none of Bradley's sentence was suspended. Bradley began to serve his sentence in the DOC on October 15, 2024.

[4] On March 5, 2025, Bradley filed a motion for “jail credit and good time allowance,” in which he acknowledged that the trial court awarded him the proper accrued time but claimed that the trial court awarded him no good time credit and that the DOC had not applied the credit time to his sentence.³ Bradley also claimed that his earliest possible release date was listed as September 5, 2027, which he insisted was incorrect and improperly increased his sentence. The trial court denied Bradley's motion that same day, noting:

Defendant did receive 587 + 196 days of good time credit at his sentencing hearing on 10-15-2024. The zero days Defendant is referring to [in his motion] is his suspended time, not his good time credit. Defendant's Plea Agreement stated zero (0) days of suspended time.

Appellant's App. Vol. II p. 2. Bradley now appeals.

Discussion and Decision

[5] Bradley claims that the DOC failed to apply the credit time he earned toward his sentence.⁴ In addressing this claim, we first note that “[b]ecause credit time is a matter of statutory right, trial courts do not have discretion in awarding or denying such credit.” Harding v. State, 27 N.E.3d 330, 331-32 (Ind. Ct. App. 2015). Two types of credit must be calculated: “ ‘(1) the credit toward the sentence a prisoner receives for time actually served, and (2) the additional credit a prisoner receives for good behavior and educational attainment.’ ” Maciaszek v. State, 75 N.E.3d 1089, 1092 (Ind. Ct. App. 2017) (quoting Purcell v. State, 721 N.E.2d 220, 222 (Ind. 1999)), trans. denied. We refer to these two types of credit as “accrued time” and “good time credit,” respectively. The trial court generally “determines the amount of initial credit time to which a defendant is entitled at the time of sentencing.” Ellis v. State, 58 N.E.3d 938, 941 (Ind. Ct. App. 2016). But after sentencing, “the DOC is responsible for modifications to credit time ․” Id. (citing Samuels v. State, 849 N.E.2d 689, 692 (Ind. Ct. App. 2006)).

[6] Bradley does not appear to challenge the calculation of his accrued time or good time credit. Instead, he claims that the DOC did not properly apply his accrued time and good time credit to his sentence. Bradley claims that none of the good time credit was applied to his sentence and that he was not awarded twenty-one days of accrued time and five days of good time credit that he spent in jail after sentencing. We cannot agree.

[7] The trial court's sentencing order and the abstract of judgment show that the trial court awarded the proper credit time to Bradley. The DOC report, included in the State's appendix, shows that the DOC has applied 587 days of pretrial accrued time and 196 days of pretrial good time credit toward Bradley's sentence. Appellee's App. Vol. II p. 2. This same report lists Bradley's projected release date as March 25, 2027,⁵ not September 5, 2027, as claimed in Bradley's motion. Thus, Bradley's claim that the DOC did not properly apply the pretrial credit time to his sentence is mistaken.

[8] Any claim Bradley has regarding the DOC's calculation of his post-trial credit must first be addressed by the DOC via its administrative procedures. See Ellis, 58 N.E.3d at 941 (noting that the DOC is statutorily required to implement a grievance procedure in which an inmate may submit grievances arising out of administrative acts that affect the inmate, including claims that the DOC wrongfully denied credit time) (citing Samuels, 849 N.E.2d at 692; Ind. Code § 11-11-1-2).

Conclusion

[9] The trial court properly denied Bradley's motion for credit time because the pretrial credit time he earned has been applied toward his sentence. We, therefore, affirm the trial court.

[10] Affirmed.

FOOTNOTES

1.   The State charged Bradley as follows: Count I—dealing in a narcotic drug, a Level 2 felony; Count II—dealing in cocaine, a Level 2 felony; Count III—dealing in methamphetamine, a Level 2 felony; Count IV—unlawful possession of a firearm by a serious violent felon, a Level 4 felony; and Count V—dealing in marijuana, a Level 6 felony.

2.   Because Bradley was convicted of a Level 2 felony and a Level 4 felony, he was assigned to Class B for purposes of calculating his credit time. See Ind. Code § 35-50-6-4(b) (providing that a person who is not a credit restricted felon who is imprisoned for a crime other than a misdemeanor or Level 6 felony is initially assigned to Class B). “A person assigned to Class B earns one day of good time credit for every three calendar days or partial calendar days the person is imprisoned for a crime.” Sims v. State, 260 N.E.3d 235 (Ind. Ct. App. 2025) (citing Ind. Code § 35-50-6-3.1(c)), trans. denied. Thus, Bradley earned one-third of 587 days, or 196 days, of good time credit.

3.   This was the second motion Bradley had filed regarding his credit time. On January 18, 2025, Bradley filed a motion to correct the abstract of judgment, in which he claimed that he was entitled to more credit than the trial court awarded. The trial court denied the motion that same day and noted that the abstract of judgment was correct. Bradley did not appeal the court's ruling on that motion.

4.   Bradley is proceeding pro se on appeal, as he did below. “[W]e, therefore, reiterate that ‘a pro se litigant is held to the same standards as a trained attorney and is afforded no inherent leniency simply by virtue of being self-represented.’ ” Stark v. State, 204 N.E.3d 957, 963 (Ind. Ct. App. 2023) (quoting Zavodnik v. Harper, 17 N.E.3d 259, 266 (Ind. 2014).

5.   This same earliest possible release date is also listed on the DOC's Offender Locator website. See https://offenderlocator.idoc.in.gov/idoc-ofs-1.0.2/ofs?previous_page=1&detail=268237 [https://perma.cc/X2CN-XJER] (last visited Nov. 24 2025).

Tavitas, Judge.

Bailey, J., and Kenworthy, J., concur.