Travis S. Chandler, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

[1] Travis Chandler appeals the Brown Circuit Court's revocation of his probation. Chandler presents one issue for our review, namely, whether the trial court abused its discretion when it admitted certain evidence during the hearing on the State's petition to revoke his probation.

[2] We affirm.

Facts and Procedural History

[3] On February 5, 2024, Chandler pleaded guilty to Level 5 felony operating a motor vehicle as a habitual traffic violator. The trial court sentenced him to four years, with 180 days executed and the balance suspended to probation. The trial court imposed common conditions of probation, including drug screens and a prohibition against possessing or using illegal drugs.

[4] From August 12, 2024, through February 6, 2025, Chandler submitted four drug screens that were positive for methamphetamine. On February 20, Chandler executed an Administrative Agreement in which he admitted that those positive drug screens were violations of the terms of his probation. He agreed to thirty days of day-reporting, and he agreed to attend and complete moral reconation therapy (“MRT”).¹

[5] On March 19, the State filed a petition to revoke Chandler's suspended sentence. In support, the State submitted an affidavit executed by Chandler's probation officer stating in relevant part that:

a. [Chandler] provided drug screens on 8/12/24 and 2/6/25. The toxicologist identified the presence of amphetamine, methamphetamine, and THC at a level indicative of methamphetamine and marijuana use while on probation;

b. [Chandler] provided drug screens on 10/3/24, 1/22/25, 2/24/25, 2/27/25 and 3/11/25. The toxicologist identified the presence of amphetamine and methamphetamine at a level indicative of methamphetamine use while on probation;

c. [Chandler] failed to report for drug screens as directed on 9/20/24, 11/21/24, 1/16/25, 1/27/25 and 2/6/25;

d. [Chandler] failed to appear for office appointments on 9/30/24, 12/13/24 and 2/11/25;

e. [Chandler] failed to report for day reporting on 2/26/25, to wit: [Chandler] was placed on day reporting as a result of an administrative agreement on 2/20/25;

f. [Chandler] has failed to begin MRT as ordered by the Court, to wit: [Chandler] completed an assessment at Centerstone on 11/20/24 and has failed to complete the program.

Appellant's App. Vol. 2, p. 59.

[6] At a fact-finding hearing on the petition, the trial court admitted into evidence the Administrative Agreement and seven positive drug screens, all signed by Chandler. Chandler admitted that his signature was on the Administrative Agreement and two of the drug screen results, but he stated that he did not recognize the signature on five of the drug screen results.² The trial court admitted the proffered exhibits into evidence over Chandler's objection. Chandler's probation officer testified about his missed day-reporting appointments and missed drug screens as well as his positive drug screens. Chandler testified that he had not intentionally used methamphetamine. He testified that he had caught a roommate putting methamphetamine in his coffee every day.

[7] The trial court found that Chandler had violated the terms of his probation by using marijuana and methamphetamine/amphetamine; by failing to report for four drug screens; by failing to report for three office appointments; and by failing to report for day-reporting on February 26, 2025. Accordingly, the trial court revoked Chandler's probation and sentenced him to two years executed. This appeal ensued.

Discussion and Decision

[8] Chandler contends that the trial court abused its discretion when it admitted seven drug screen results into evidence during the factfinding hearing. We review a trial court's decision to admit or exclude evidence in a probation revocation proceeding for abuse of discretion. Votra v. State, 121 N.E.3d 1108, 1113 (Ind. Ct. App. 2019). We will reverse only where the trial court's decision is clearly against the logic and effect of the facts and circumstances. Id.

[9] “It is well settled that probationers are not entitled to the full array of constitutional rights afforded defendants at trial.” Cox v. State, 706 N.E.2d 547, 549 (Ind. 1999). While a probation revocation hearing has certain due process requirements, it is not to be equated with an adversarial criminal proceeding. Id. at 549-50. “Rather, it is a narrow inquiry, and its procedures are to be more flexible.” Id. at 550. This flexibility is necessary to permit the court to exercise its inherent power to enforce obedience to its lawful orders. Id. And, because of this flexibility, strict rules of evidence do not apply in probation revocation hearings. Id.; see also Ind. Evidence Rule 101(d)(2) (providing that rules of evidence do not apply in proceedings relating to probation). Therefore, in probation revocation hearings, judges may consider any relevant evidence bearing some substantial indicia of reliability. Cox, 706 N.E.2d at 551.

[10] On appeal, Chandler argues that the seven drug screen results were inadmissible under various evidence rules. Chandler acknowledges that, under Indiana Evidence Rule 101(d)(2), the rules of evidence do not apply to probation revocation proceedings. But he argues that probation revocation proceedings are analogous to indirect contempt proceedings, which are subject to the evidence rules. Chandler urges us to “refer this matter to the Supreme Court Committee on Rules of Practice and Procedure, serving as the Evidence Rules Review Committee, for its review and revision of Ind. Evidence Rule 101 to eliminate the exception of proceedings related to probation from subsection (d)(2), should it so choose.” Appellant's Br. at 17-18. We decline Chandler's invitation, although we note that anyone may submit a proposed rule change to the Rules Committee.³ We hold that the trial court did not abuse its discretion in the admission of evidence.

[11] The State presented ample evidence bearing sufficient indicia of reliability to support the revocation of Chandler's probation. First, in the Administrative Agreement Chandler executed in February 2025, Chandler admitted to positive drug screens on August 12, 2024, October 3, 2024, January 22, 2025, and February 6, 2025. Second, the State presented evidence regarding how the drug screens were conducted, and each drug screen exhibit included a signed chain of custody form. Third, the trial court found that Chandler was not credible when he denied that the signatures on five of the drug screen exhibits were not his, and our review of the exhibits is consistent with that finding. Chandler has not shown that the trial court abused its discretion when it admitted the drug screens into evidence.

[12] In any event, any error in the admission of the drug screens into evidence was harmless. As the State correctly points out, we will affirm the revocation of probation where “there is substantial evidence of probative value to support the trial court's conclusion that a probationer has violated any condition of probation.” Murdock v. State, 10 N.E.3d 1265, 1267 (Ind. 2014) (citation omitted, emphasis added). Chandler does not challenge the sufficiency of the evidence regarding his missed appointments, missed drug screens, and missed day reporting. For all of these reasons, we affirm the trial court's revocation of Chandler's probation.

[13] Affirmed.

FOOTNOTES

1.   MRT is a program that includes education and counseling.

2.   The signatures on each of the drug screen results admitted into evidence look substantially similar, and the trial court found Chandler's testimony on this issue not credible.

3.   See https://www.in.gov/courts/iocs/committees/rules/rule-proposal.

Mathias, Judge.

Pyle, J., and Weissmann, J., concur