EDWARDS v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] Jacob Robert Edwards appeals the sentences imposed following his convictions for theft of a firearm, a Level 5 felony, and robbery resulting in bodily injury, a Level 3 felony. Edwards contends that the trial court abused its discretion in ordering those sentences to run consecutively to those imposed for offenses that he committed in Illinois and Michigan. Edwards claims that this alleged improper sentence requires remand for a recalculation of credit time.

[2] We affirm.

Facts and Procedural History

[3] After Edwards robbed a bank in New Buffalo, Michigan, on January 17, 2023, he immediately drove to Indiana. Two days later, Edwards stole a pistol from Brandon Fitzmorris in Tippecanoe County and injured him while forcibly taking his truck. Edwards fled the scene and on January 20, 2023, he was arrested in Illinois and charged with several offenses including aggravated assault.

[4] Edwards was convicted of the assault charge in Illinois and sentenced for that offense on August 14, 2023, to twenty-four months of probation with credit for time served. On November 13, 2024, Edwards was convicted and sentenced in federal court for the Michigan bank robbery. Edwards was ordered to serve fifteen months of incarceration with three years of supervised release.

[5] Pursuant to a plea agreement, Edwards was convicted of the Tippecanoe offenses and sentenced on October 29, 2025, to six years of incarceration for robbery resulting in serious bodily injury and to three years of incarceration for theft of a firearm to be served at the Indiana Department of Correction (DOC). The trial court ordered those sentences to run consecutive to each other and consecutive to the Illinois and Michigan sentences.

[6] At the sentencing hearing, it was established that Edwards received credit in Illinois for time served in that state. The trial court explained that the time Edwards was incarcerated in Michigan and Illinois would not apply as credit time in the Indiana cases.

[7] Edwards now appeals.

Discussion and Decision

[8] Edwards contends that he must be resentenced on the Indiana convictions because the trial court erred by failing to state the reasons for ordering those sentences to run consecutive to the Illinois and Michigan sentences. Edwards further maintains that the pretrial jail time credit he was awarded “is affected by the ․ improper imposition of consecutive sentences” and, therefore, his credit time must be recalculated. Appellant's Brief at 13.

[9] A trial court abuses its discretion at sentencing if it: (1) fails to provide a sentencing statement at all; (2) relies on aggravating or mitigating factors that are not supported by the record; (3) fails to find factors that are clearly supported by the record and were advanced for consideration; or (4) relies upon reasons that are invalid as a matter of law. Anglemyer v. State, 868 N.E.2d 482, 490-91 (Ind. 2007), clarified on reh'g, 875 N.E.2d 218 (2007).

[10] Notwithstanding Edwards's abuse of discretion claim, Ind. Code § 35-50-1-2 provides that a trial court may order terms of imprisonment to be served consecutively even if the sentences are not imposed “at the same time.” Our Supreme Court has construed this statute to grant trial courts authority “to impose a sentence consecutive to that of another jurisdiction.” Sweeney v. State, 704 N.E.2d 86, 110 (Ind. 1998); see also Carrion v. State, 619 N.E.2d 972, 973 (Ind. Ct. App. 1993) (the trial court properly ordered the defendant's sentence for crimes committed in Indiana to be served consecutively to sentences previously imposed in another state), trans. denied. And because consecutive sentencing to another jurisdiction's sentence rests with the trial court's discretion, the trial court need not state the reasons for ordering consecutive sentences. See Sweeney, 704 N.E.2d at 110. We therefore reject Edwards's claim that he must be resentenced.

[11] Edwards also claims that his pretrial credit time was “adversely impacted” because the trial court ordered his sentences to run consecutive to those imposed in the other jurisdictions. Appellant's Brief at 9. Hence, Edwards contends that remand is required for a recalculation of his credit time. Contrary to Edwards's argument, a defendant is not entitled to credit on his Indiana sentence for the time that he is incarcerated in another jurisdiction for a different offense. Woodson v. State, 383 N.E.2d 1096, 1101 (Ind. Ct. App. 1978).

[12] Here, Edwards admitted that he received credit time in Illinois for the offenses committed there. He now is essentially requesting double credit, and the trial court informed Edwards that he could not “double dip ․ [and] ․ take it there and here.” Transcript Vol. II at 36. Indeed, defendants are not entitled to double credit. See State v. Lotaki, 4 N.E.3d 656, 658 (Ind. 2014). To be sure, “credit is to be applied for confinement time that is a result of the charge for which the defendant is being sentenced. In essence, each court is responsible only for crediting time in confinement as a result of the charge for which that court is sentencing the defendant.” Carneal v. State, 859 N.E.2d 1255, 1258 (Ind. Ct. App. 2007), trans. denied. Therefore, any time that Edwards was confined for committing aggravated assault in Illinois, and any time that he spent incarcerated in the federal system for the Michigan bank robbery do not apply as credit towards his time served for the sentence imposed on the Indiana convictions. See id. Edwards has failed to show how his credit time was adversely affected by the imposition of consecutive sentences. We therefore conclude that the trial court did not abuse its discretion in sentencing him.

[13] Judgment affirmed.

Altice, Judge.

Vaidik, J. and Foley, J., concur.