Jan. 28, 2026

Indiana Court of Appeals
Michael L. Williams v. State of Indiana
25A-CR-687

Criminal. Appeal from the Boone Circuit Court, Judge Lori N. Schein. Affirms the trial court’s denial of Michael Williams’s request for credit time for the period he was on pretrial GPS monitoring. Holds that pretrial GPS monitoring, which the trial court expressly stated was not home detention, does not constitute “imprisonment” or “confinement” under Indiana Code 35-50-6 as in effect at the time of the offenses. Concludes Williams retained substantial freedom of movement, was not subject to direct supervision comparable to confinement, and experienced restrictions typical of pretrial release rather than custodial restraint. Further holds that because Williams was not confined, he was entitled to neither accrued time nor good time credit for the GPS-monitoring period. Accordingly, affirms the trial court’s calculation of credit time and the aggregate eleven-year executed sentence. Appellant’s attorney: Allan W. Reid, Foley Panszi Law, LLC. Appellee’s attorneys: Office of the Indiana Attorney General (Theodore E. Rokita; J.T. Whitehead, Deputy Attorney General).

Indiana Court of Appeals
Callie R. Burke v. Indiana Department of Correction and Indiana State Personnel Department
No. 25A-MI-1313

Civil. Appeal from the La Porte Circuit Court, Judge Julianne K. Havens. Affirms in part, reverses in part, and remands. Affirms the trial court’s dismissal of Burke’s petition for judicial review of a State Employees’ Appeals Commission (SEAC) decision because Burke failed to timely file the agency record as required by the Indiana Administrative Orders and Procedures Act (AOPA), and under the Indiana Supreme Court’s bright-line rule in Teaching Our Posterity Success, Inc. v. Indiana Department of Education, dismissal was mandatory. Holds the statutory amendments shifting responsibility for filing the agency record to the agency apply prospectively only and did not excuse Burke’s noncompliance. Further holds that, under Indiana’s notice pleading standards, Burke’s petition also included a claim for declaratory judgment. Concludes that Burke’s challenge to her employee classification and the State Personnel Director’s allocation decisions could have been addressed through the administrative and judicial review process and therefore was properly dismissed with the petition for judicial review. Holds, however, that Burke’s facial constitutional challenge to the Civil Service Reform Act under the Single Subject Clause of the Indiana Constitution could not be resolved by SEAC, exhaustion was excused as futile, and the trial court erred in dismissing that declaratory judgment claim. Remands for further proceedings limited to the facial constitutional challenge. Appellant’s attorneys: Shaw R. Friedman and Laura M. Nirenberg, Friedman & Associates, P.C. Appellees’ attorneys: Office of the Indiana Attorney General (Theodore E. Rokita; Samuel J. Dayton, Supervising Deputy Attorney General).