Jesse Doyle, Jr., Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

[1] In May 2011, Jesse Doyle, Jr. committed Class A felony child molesting for which he pleaded guilty in May 2015 pursuant to a plea agreement. The State established a factual basis for Doyle's guilty plea, the trial court accepted the plea agreement, and the court sentenced Doyle to an executed term of thirty years in the Department of Correction.

[2] In November 2025, Doyle filed a Trial Rule 60(B)(6) motion for relief from his judgment of conviction. Trial Rule 60(B)(6) provides that a court may relieve a party from a judgment when that judgment is “void.” A motion for relief under Trial Rule 60(B)(6) must be filed “within a reasonable time” following the judgment. Ind. Trial Rule 60(B). The trial court denied Doyle's motion.

[3] On appeal, Doyle contends that the trial court erred when it denied his Trial Rule 60(B)(6) motion because, had he gone to trial, he might have been able to have certain evidence against him deemed inadmissible. According to Doyle, that same evidence was part of the State's factual basis in support of his guilty plea. Thus, he continues, the State failed to present an adequate factual basis for his guilty plea, and, as a trial court cannot accept a guilty plea without an adequate factual basis, his judgment of conviction must be “void” under Indiana Trial Rule 60(B)(6).

[4] Doyle's understanding of the factual-basis requirement for a guilty plea and his understanding of Trial Rule 60(B)(6) are contrary to law. As our Supreme Court has explained:

An Indiana court cannot accept a guilty plea unless there is an adequate factual basis for the plea. Ind. Code § 35-35-1-3(b) (2008). The purpose of the factual basis requirement is to ensure that a person who pleads guilty is truly guilty. Butler v. State, 658 N.E.2d 72 (Ind. 1995). As the ABA standards put it, the court should satisfy itself that “the defendant could be convicted if he or she elected to stand trial.” ABA Standards for Criminal Justice Pleas of Guilty 65 (3d. ed. 1999). “[A] factual basis exists when there is evidence about the elements of the crime from which a court could conclude that the defendant is guilty.” Butler, 658 N.E.2d at 77. The presentation about facts need not prove guilt beyond a reasonable doubt. Id. The original trial court's determination that the factual basis was adequate is clothed with the presumption of correctness. See id. We will only set aside the trial court's acceptance of a guilty plea for an abuse of discretion. Id.

In light of those declared purposes for the factual basis requirements, claims about omissions in the factual basis have been unavailing when the omissions do not seem to demonstrate doubt about actual guilt․

State v. Cooper, 935 N.E.2d 146, 150 (Ind. 2010) (alteration original to Cooper).

[5] Indiana's appellate courts have long permitted the factual basis for a guilty plea to be based on what, at trial, might be inadmissible evidence. For example, in Hitlaw v. State, 178 Ind. App. 124, 126-27, 381 N.E.2d 527, 528 (1978), we held that, while the documents establishing the factual basis for the defendant's plea were “not presented under oath,” nonetheless they were “sufficient” to show the defendant's guilt. Our Supreme Court has held likewise, expressly agreeing with Hitlaw and permitting statements within a probable-cause affidavit to be part of the factual basis underlying a guilty plea. Moredock v. State, 540 N.E.2d 1230, 1231 (Ind. 1989); cf. Brown v. State, 929 N.E.2d 204, 207 (Ind. 2010) (“Indeed, because improperly seized evidence is frequently highly relevant, its admission ordinarily does not cause us to question guilt.”). Thus, Doyle's attempt to have his judgment of conviction declared void on the theory that the factual basis underlying that judgment was based on inadmissible evidence is contrary to law.

[6] And Trial Rule 60(B)(6) is not applicable to a defendant who pleads guilty and then later seeks to challenge the adequacy of the factual basis underlying his guilty plea. As our Supreme Court has explained:

Trial Rule 60(B)(6) allows a party to move for relief at any time if “the judgment is void.” T.R. 60(B)(6); see also Anderson v. Wayne Post 64, Am. Legion Corp., 4 N.E.3d 1200, 1205 (Ind. Ct. App. 2014), trans. denied. So, to be entitled to relief, the party must establish that the judgment is void, not voidable. Koonce v. Finney, 68 N.E.3d 1086, 1090 (Ind. Ct. App. 2017), trans. denied. The distinction between these two terms is “no mere semantic quibble.” Stidham v. Whelchel, 698 N.E.2d 1152, 1154 (Ind. 1998). While a void judgment “is a complete nullity” without legal effect from its inception, id. (quoting 46 Am. Jur. 2d Judgments § 31 (1994)), a voidable judgment “is capable of confirmation or ratification,” making it subject to ordinary appellate or other direct procedures to correct it, id. (quoting 46 Am. Jur. 2d Judgments § 30 (1994)).

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[A] trial court's judgment is void if the court lacks personal jurisdiction, subject matter jurisdiction, or the authority to render the judgment. That said, we construe “authority” [under “authority to render the judgment”] narrowly to distinguish void errors from voidable legal or procedural errors. See K.S., 849 N.E.2d at 541. There is a distinct difference between a judgment that the law does not authorize under any circumstances (a void judgment), and a judgment authorized by law but derived in violation of law (a voidable judgment). In the latter scenario, the trial court still has the requisite authority to act, and thus, the error is a procedural irregularity that can be cured. See 46 Am. Jur. 2d Judgments § 15 (2023) (“The fact that a [trial] court acts in violation of a statute does not mean that the resulting judgment is void.”).

T.D. v. State, 219 N.E.3d 719, 725-27 (Ind. 2023) (last alteration original to T.D.).

[7] Here, there is no question that the trial court had subject matter jurisdiction over Doyle's criminal case, that the court had personal jurisdiction over Doyle, and that the court had the authority to render the judgment of conviction. Accordingly, Doyle's reliance on Trial Rule 60(B)(6) fails.

[8] For all of these reasons, we affirm the trial court's denial of Doyle's motion for relief from his judgment of conviction.

[9] Affirmed.

Mathias, Judge.

Bradford, J., and Pyle, J., concur.