GOODLOE v. STATE (2025)

MEMORANDUM DECISION

Case Summary

[1] After Dequinci Goodloe pled guilty to Level 5 felony domestic battery, he was ordered to serve a term in community corrections, to be followed by probation. In February of 2025, the State alleged that Goodloe had violated the terms of the community-corrections placement by having contact with his victim in violation of a no-contact order, failing to report for a drug screen and complete a substance-abuse evaluation, and failing to enroll in a batterer's-intervention program. The State also alleged that Goodloe had violated the terms of his probation by violating the terms of the community-corrections placement. Goodloe contends that the State failed to give him adequate notice of the allegations against him in its request to have his probation revoked. We affirm.

Facts and Procedural History

[2] On September 30, 2024, Goodloe pled guilty to Level 5 felony domestic battery on C.N., and the trial court sentenced him to 1095 days of incarceration, 365 of which were to be executed on home detention, followed by 730 days suspended to probation. The terms of Goodloe's probation and community-corrections placements both included the requirement that he complete a substance-abuse evaluation and twenty-six weeks of domestic-violence counseling or a batterer's-intervention program, submit to drug screening, and have no contact with C.N. or Dayshaun Thompson. On February 4, 2025, C.N. informed the authorities that Goodloe had been contacting her. C.N. provided an affidavit to community corrections department stating that Goodloe had contacted her “via cellphone calls + text messages for sometime now demanding I speak with him and threatening oo [(sic)] cause harm to me if I don't[.]” Ex. Vol. p. 7.

[3] On February 7, 2025, the State filed a notice of community-corrections violation (“the First Notice”) alleging that Goodloe had violated his no-contact order by calling and texting C.N. On February 11, 2025, the State amended the First Notice to add allegations that Goodloe had failed to report for a drug screen, complete a substance-abuse evaluation, or enroll in a batterer's-intervention program. On February 12, 2025, the State alleged that Goodloe had violated the terms of his probation (“the Second Notice”) by “fail[ing] to comply with Marion County Community Corrections (MCCC) placement. Marion County Community Corrections filed a Notice of Violation on 2/11/2025.” Appellant's App. Vol. II p. 174. On March 12, 2025, the State amended the First Notice to include additional allegations that he had violated the no-contact order.

[4] At the evidentiary hearing on the First and Second Notices on March 13, 2025, the trial court indicated that “[t]his matter is set for a hearing on violation of community corrections [a]nd probation.” Tr. Vol. II p. 33. Goodloe admitted to the failure to submit a drug screen and to violating the court-ordered conditions. As for the no-contact order, Goodloe's case manager offered into evidence C.N.’s affidavit, the text messages Goodloe had sent to her, and Marion County Jail telephone records with calls he had made to C.N.’s number.

[5] At the conclusion of the evidentiary hearing, the trial court found that Goodloe had violated his no-contact order, accepted his admissions to the other allegations, and found that he had violated the terms of both his probation and community-corrections placement. The trial court revoked Goodloe's community-corrections placement and probation and ordered that he execute the balance of his sentence in the Indiana Department of Correction.

Discussion and Decision

[6] Goodloe's only argument is that the trial court erred in revoking his probation because the State's Second Notice was insufficiently detailed to inform him of the nature of the allegations or allow him to prepare a defense. Goodloe correctly notes that because probation-revocation proceedings implicate a probationer's liberty interests, they are subject to the Fourteenth Amendment's due-process strictures. Gagnon v. Scarpelli, 411 U.S. 778, 786 (1973) (citing Morrissey v. Brewer, 408 U.S. 471, 489 (1972)). Among the rights granted to a probationer for whom revocation is sought is “written notice of the claimed violations of [probation.]” Id. It is an error for a probation revocation to be based upon a violation for which a probationer did not receive adequate notice. Bovie v. State, 760 N.E.2d 1195, 1199 (Ind. Ct. App. 2002). Written notice must be sufficiently detailed to allow the probationer to prepare an adequate defense. Hammann v. State, 210 N.E.3d 823, 831 (Ind. Ct. App. 2023), trans. denied.

[7] Under the circumstances of this case, we conclude the Second Notice was sufficient to inform Goodloe of the nature of the allegations against him and allow him to prepare a defense. As mentioned, the Second Notice alleged that Goodloe had violated the terms of his probation by “fail[ing] to comply with Marion County Community Corrections (MCCC) placement. Marion County Community Corrections filed [the First Notice] on 2/11/2025.” Appellant's App. Vol. II p. 174. The Second Notice specifically referred to the First Notice, which had been filed the day before and contained three specific allegations that, if true, would also violate the terms of Goodloe's probation. Any reasonable person would have understood this to mean that the State was alleging that Goodloe had violated the terms of his probation by doing the exact same things he had done to violate the terms of his community-corrections placement. We conclude that the Second Notice, although it could have been written more clearly, was nonetheless sufficiently detailed to provide Goodloe with notice of the allegations against him and enable him to prepare an adequate defense.

[8] Goodloe draws our attention to Long v. State, 717 N.E.2d 1238 (Ind. Ct. App. 1999), and Harder v. State, 501 N.E.2d 1117 (Ind. Ct. App. 1986), two cases in which we concluded that a probationer's due-process rights had been violated. In Harder, the allegation had been that the probationer had driven while “Intoxicated, Per Se” while probation had been revoked on the ground that she had driven “impaired due to alcohol consumption[.]” See Harder, 501 N.E.2d at 1121. In Long, the State alleged that the probationer had “ ‘tampered’ with his ankle transmitter[,]” while probation had been revoked because he had “attempted to fix” it, a different ground. See Long, 717 N.E.2d at 1240. Harder and Long do not help Goodloe, however, because they are distinguishable on the facts. The problem in both of those cases was that the State had alleged one thing only to prove another, which is not what happened here. Here, the State proved (or Goodloe admitted to) exactly what it had alleged.

[9] In any event, even if we assume that a due-process violation somehow occurred here, any such violation could only be considered harmless. “A federal constitutional error is harmless if it is clear beyond a reasonable doubt that it did not affect the judgment.” Pope v. State, 853 N.E.2d 970, 973 (Ind. Ct. App. 2006) (citing Chapman v. Cal., 386 U.S. 18, 23 (1967), and McCorker v. State, 797 N.E.2d 257, 266 (Ind. 2003)); see also Bussberg v. State, 827 N.E.2d 37, 44 (Ind. Ct. App. 2005) (“However, [the State's failure to give Bussberg sufficient notice of alleged probation violations] is harmless error in this case because Bussberg was found to have ingested methamphetamine, a violation for which he did receive notice[.]”), trans. denied. We do not see how Goodloe's defense was prejudiced—or even how it could have been prejudiced—by any due-process violation that might have occurred. Put another way, even if we assume that Goodloe had had absolutely no idea what sort of evidence the State was going to use to prove that he had violated the terms of his probation, the only evidence it actually did present on that point was the exact same evidence Goodloe was already prepared for. Goodloe has failed to carry his burden to establish harmful error in this proceeding.

[10] The judgment of the trial court is affirmed.

Bradford, Judge.

May, J., and Mathias, J., concur.