CHAVIRA v. STATE (2026)

MEMORANDUM DECISION

[1] Aiedan Chavira threatened his girlfriend with a knife and physically assaulted her in the presence of her minor child. He was soon arrested and found to be in possession of a controlled substance. And later, while in jail, he sent his girlfriend threatening letters, urging her not to cooperate with authorities. For all this, Chavira was sentenced to a total of 61/212 years in prison on two felony and two misdemeanor convictions. Chavira appeals his sentence, arguing that the trial court failed to recognize his post-traumatic stress disorder (PTSD) diagnosis as a mitigating circumstance. Because the record shows that the trial court considered Chavira's PTSD, we affirm.

Facts

[2] In September 2024, Chavira and his girlfriend, S.R., lived together with S.R.’s three-year-old child. Their relationship was volatile and marked by frequent conflict, and one day, they became involved in a heated argument inside their home. During the confrontation, Chavira armed himself with a steak knife and chased S.R. around with it. He eventually caught up with S.R., threw her to ground, and punched her in the leg. S.R.’s child was present for all these events.

[3] Chavira fled the home on his moped after the incident, and police later found him hiding in a dumpster at a nearby apartment complex. From his moped, police recovered the knife Chavira used during the incident as well as paraphernalia that tested positive for amphetamine and oxycodone.

[4] The State initially charged Chavira with three crimes: Level 6 felony domestic battery, Level 5 felony intimidation, and Class A misdemeanor possession of a controlled substance. But while Chavira was in jail, awaiting trial, he sent letters to S.R, urging her not to cooperate with authorities and threatening her if she did. The State therefore added a fourth charge: Level 5 felony obstruction of justice. A jury found Chavira guilty as charged of domestic battery, possession of controlled substance, and obstruction of justice. However, on the felony intimidation charge, the jury found him guilty of the lesser included offense of Class A misdemeanor intimidation. The trial court entered judgment of conviction accordingly.

[5] At sentencing, the trial court identified several aggravating circumstances, including Chavira's extensive juvenile and adult criminal history, his pattern of violent behavior, the nature and circumstances of the offenses, his continued threats toward S.R., and the commission of the offenses in the presence of a minor. The court noted Chavira's significant childhood trauma and resulting mental health issues but assigned these circumstances diminished weight because Chavira had repeatedly refused opportunities to address them.

[6] The trial court ultimately sentenced Chavira to a total of 61/212 years in prison, with 1 year suspended to probation. He appeals this sentence.

Discussion and Decision

[7] Sentencing decisions “rest within the discretion of the trial court and are reviewed on appeal ․ 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. One way a trial court abuses its discretion is by omitting from its sentencing statement a mitigating circumstance that is both significant and clearly supported by the record. Id. at 490-91. Chavira claims the trial court abused its discretion by failing to recognize his PTSD diagnosis as a mitigating circumstance at sentencing.¹ We find no such error.

[8] Chavira's PTSD “stem[s] from his extensive trauma history during childhood and adolescence.” Appellant's Br., p. 18. And the trial court noted Chavira's “childhood trauma” as a mitigating circumstance in both its oral and written sentencing statements. App. Vol. III, p. 11; Tr. Vol. II, p. 68. The court also recognized that such trauma “doesn't automatically go away” and that Chavira needed “mental health services” to address it. Tr. Vol. II, p. 68. But the court, did not assign these circumstances significant weight because Chavira had been given multiple opportunities to address them through services but “flat out refused to participate.” Id.

[9] Chavira argues that the trial court should have distinguished his childhood trauma and PTSD as two separate mitigators. They are, after all, distinct concepts: the former being a diagnosed mental-health condition, and the latter being a life experience that may give rise to such a condition. Here, however, the trial court's sentencing statements reflect that it considered both. Doing so without using the words “PTSD” or “diagnosis” was not an abuse of discretion.

[10] To the extent Chavira argues that the trial court should have afforded greater mitigating weight to his childhood trauma and PTSD diagnosis, his claim amounts to a request that we reweigh the evidence, which we will not do. A trial court is not required to accept a defendant's contention of what constitutes a mitigating factor. Mehringer v. State, 152 N.E.3d 667, 673 (Ind. Ct. App. 2020). Nor is the court “obligated to explain why,” after hearing argument from counsel on a proffered mitigating circumstance, it did not find the circumstance mitigating. Anglemyer, 868 N.E.2d. at 493 (citing Fugate v. State, 608 N.E.2d 1370, 1374 (Ind. 1993))

[11] Moreover, even if the trial court had failed to properly address Chavira's mitigating factors, 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 factors. Anglemyer, 868 N.E.2d. at 491. Given the serious and violent nature of the offenses, which involved threats with a deadly weapon and physical harm to the victim in the presence of a minor, as well as Chavira's extensive juvenile and adult criminal history and his continued threatening behavior toward the victim, we can say with confidence that express recognition of Chavira's mitigating circumstances would not have resulted in the imposition of a different sentence. See Bryant v. State, 959 N.E.2d 315, 322-23 (Ind. Ct. App. 2011) (holding that alleged failure to find mitigating circumstances was harmless because defendant had extensive criminal record). We therefore find no reversible error in the trial court's determination of Chavira's mitigating circumstances.

Conclusion

[12] The record shows that the trial court considered Chavira's PTSD diagnosis and acted within its discretion in assigning this circumstance limited weight. Because Chavira has not demonstrated that the court ignored significant mitigating circumstances or otherwise abused its discretion, we affirm his 61/212year sentence.

FOOTNOTES

1.   Chavira describes his sentence as “manifestly unreasonable.” Appellant's Br., pp. 15, 19; Appellant's Reply Br., p. 4. When Indiana Appellate Rule 7(B) was revised in 2002 (effective January 1, 2003), the “manifestly unreasonable” standard for reviewing sentences was replaced with the “inappropriate” standard. Saylor v. Indiana, 808 N.E.2d 646, 650 (Ind. 2004). Chavira does not challenge his sentence under the new standard.

Weissmann, Judge.

Tavitas, C.J., and Foley, J., concur.