CHANDLER v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] Aaron Darnell Chandler appeals his sentence following his conviction for domestic battery, as a Class A misdemeanor. Chandler raises one issue for our review, namely, whether the court abused its discretion when it sentenced him. We affirm.

Facts and Procedural History

[2] In March 2025, D.R. was in a relationship with Chandler, and the two of them were living together. On March 17, D.R. returned home from work, and she and Chandler “hung out, watched TV, drank,” and ate dinner. Tr. Vol. 2 at 7. Sometime around midnight on March 18, Chandler and D.R. got into an argument about a past incident of D.R.’s infidelity, and Chandler “snapped.” Id. Chandler “slapped” D.R. in the face, “pulled [her] hair,” and shook her like she was “a rag doll.” Id. As a result, D.R. sustained some pain and some “scratches” on her face. Id. at 8. After the altercation ended, D.R. told her sister, who reported it to the police. An officer arrived on the scene, observed scratches on D.R.’s face, and arrested Chandler.

[3] The State charged Chandler with domestic battery, as a Class A misdemeanor (Count 1), and battery, as a Class A misdemeanor (Count 2). The trial court held a bench trial on Chandler's charges on July 28. During the trial, D.R. testified about the offense. At the conclusion of the trial, the court found Chandler guilty of both Counts 1 and 2 but merged the charges and entered judgment of conviction only on Count 1.

[4] The court then proceeded to sentencing. Prior to announcing a sentence, the court asked: “What do we have here? I'm looking at his full history. He's got one of these of confinement․ He's got one of these [for domestic battery] back in ’16. Was it the same victim in ’16 or someone else?” Id. at 41. The State responded that it was a “[d]ifferent victim.” Id. Chandler argued that it was “nearly a decade ago” and that he had gone “nine years without any criminal history.” Id. at 41. The court then sentenced Chandler to 365 days, with 347 days suspended to probation. After announcing that sentence, the court specifically noted that it was giving Chandler “deference” because “he hasn't had a DV case in a while.” Id. at 42. This appeal ensued.

Discussion and Decision

[5] Chandler's only argument on appeal is that the trial court “improperly relied” on a prior charge, which we interpret as an argument that the court abused its discretion when it sentenced him.¹ Appellant's Br. at 7. Sentencing decisions lie within the sound discretion of the trial court. Cardwell v. State, 895 N.E.2d 1219, 1222 (Ind. 2008). An abuse of discretion occurs if the decision is “clearly against the logic and effect of the facts and circumstances before the court, or the reasonable, probable, and actual deductions to be drawn therefrom.” Gross v. State, 22 N.E.3d 863, 869 (Ind. Ct. App. 2014), (citation omitted), trans. denied.

[6] A trial court abuses its discretion in sentencing if it does any of the following:

(1) fails “to enter a sentencing statement at all;” (2) enters “a sentencing statement that explains reasons for imposing a sentence—including a finding of aggravating and mitigating factors if any—but the record does not support the reasons;” (3) enters a sentencing statement that “omits reasons that are clearly supported by the record and advanced for consideration;” or (4) considers reasons that “are improper as a matter of law.”

Id. (quoting Anglemyer v. State, 868 N.E.2d 482, 490-91 (Ind.), clarified on reh'g on other grounds, 875 N.E.2d 218 (Ind. 2007)).

[7] The sentence for a Class A misdemeanor may not exceed one year. See Ind. Code § 35-50-3-2. And, here, the court sentenced Chandler to 365 days, with 347 days suspended to probation. On appeal, Chandler argues that the court abused its discretion when it sentenced him because it relied on his domestic battery charge from 2016, which had been dismissed. And, as such, he maintains that his sentence is “improper.” Appellant's Br. at 8. Stated differently, the crux of Chandler's argument is that the court relied on an improper aggravator when it sentenced him.

[8] Chandler is correct that the court referenced his prior domestic battery charge from 2016, and he is correct that that charge was ultimately dismissed. See Appellant's App. Vol. 2 at 17. But, contrary to Chandler's argument on appeal, it is clear that the court did not rely on that prior, dismissed charge when it sentenced him. Rather, during a review of Chandler's “full history” prior to sentencing, the court simply noted that he had “one of these [for domestic battery] back in ‘16.” Tr. Vol. 2 at 41. In other words, the court merely acknowledged the existence of the prior charge; it did not in any way state that it was using that prior charge as an aggravator. And this interpretation is further supported by the fact that the court specifically announced that it gave Chandler “deference” because he “hasn't had a DV case in a while.” Id. at 42. Thus, the court did not abuse its discretion when it sentenced Chandler.

[9] In any event, even if we were to agree that the court had abused its discretion when it sentenced him, “where the trial court abuses its discretion in sentencing a defendant, we need not remand for resentencing if we can ‘say with confidence that the trial court would have imposed the same sentence had it properly considered reasons that enjoy support in the record.’ ” Vega v. State, 119 N.E.3d 193, 203 (Ind. Ct. App. 2019) (quoting Anglemyer, 868 N.E.2d at 491). And, here, we can say with confidence that the court would have imposed the same sentence—365 days with 347 days suspended to probation—even without consideration of the dismissed domestic battery charge. Indeed, Chandler's criminal history is extensive, dating back to the early 1990s, and it includes numerous convictions for both felonies and misdemeanors. As such, even if the court abused its discretion, remand for resentencing would not be necessary. We therefore affirm Chandler's sentence.

[10] Affirmed.

FOOTNOTES

1.   Chandler does not specifically argue that the court “abused its discretion” when it sentenced him, and the only standard of review he provides relates to claims of insufficiency of the evidence.

Bailey, Judge.

Vaidik, J., and Scheele, J., concur.