March 6, 2026

Indiana Court of Appeals
Zachary Matthew Loveless v. State of Indiana
No. 25A-CR-1794

Criminal. Appeal from the Hancock Superior Court, Judge Dan E. Marshall. Judge May writes that the court affirms the trial court’s denial of Loveless’s motion to correct error seeking additional credit time after his probation was revoked. Holds Loveless was not entitled to credit toward his Hancock County sentence for time he spent incarcerated in the Marion County and Hamilton County jails because those periods of confinement were connected to separate criminal matters in those counties rather than the Hancock County case. Further holds that under the applicable test for credit time, confinement must result from the charge for which the sentence was imposed, and Loveless’s out-of-county confinement was attributable to other cases. Notes that although the credit time does not apply to the Hancock County sentence, Loveless may seek appropriate credit in the other jurisdictions where the confinement occurred. Judges Altice and Foley concur. Appellant’s attorney: Katherine D. Jack. Appellee’s attorney: Office of the Indiana Attorney General.

Indiana Court of Appeals
Gregory C. Guilfoyle v. State of Indiana
No. 25A-CR-1406

Criminal. Appeal from the Franklin Circuit Court, Special Judge Brian D. Hill. Judge Felix writes that the court affirms Guilfoyle’s convictions but revises his sentence. Holds the jury did not err in rejecting Guilfoyle’s insanity defense and finding him guilty but mentally ill, noting conflicting expert testimony regarding whether he could appreciate the wrongfulness of his conduct and emphasizing that the jury was free to credit the State’s expert and other evidence indicating Guilfoyle understood the nature of his actions. Further holds Guilfoyle’s aggregate 100-year sentence is inappropriate under Indiana Appellate Rule 7(B) in light of his mental illness, lack of criminal history, prior employment and volunteer service as a police officer and his current paralysis resulting from the shootout with law enforcement. Concludes the sentence should be revised to 80 years while leaving the convictions intact and remands with instructions to issue an amended sentencing order. Judges Tavitas and Vaidik concur. Appellant’s attorney: Cara Schaefer Wieneke. Appellee’s attorney: Office of the Indiana Attorney General.

Indiana Court of Appeals
Christopher R. Cleary v. Charles Morlan
No. 25A-PL-1590

Civil. Appeal from the LaPorte Superior Court, Judge Richard R. Stalbrink Jr. Judge Felix writes that the court affirms the trial court’s judgment foreclosing a mechanic’s lien filed by Morlan after Cleary refused to pay $9,000 for electrical work performed on a newly constructed house. Holds the Indiana Home Improvement Contracts Act does not apply because Morlan’s work involved wiring a newly constructed house and therefore was not a “real property improvement,” which the statute contemplates as work performed on existing residential real property. Further holds the trial court did not err in determining the parties’ oral agreement was for labor only and that Cleary breached the agreement by failing to pay, rejecting Cleary’s argument that the agreement was unenforceable for lacking an essential term. Concludes Morlan, as the prevailing lienholder, is entitled to reasonable appellate attorney fees under the mechanic’s lien statute and remands for a determination of those fees. Judges May and Mathias concur. Appellant’s attorney: Bradley J. Adamsky. Appellee’s attorney: Michael S. Bergerson.

Indiana Court of Appeals
Jayla Anderson v. Advantix Development Corporation a/m/a for 34 E Marion LP
No. 25A-EV-1738

Civil. Appeal from the Grant Superior Court, Judge Jason D. McVicker. Judge May writes that the court reverses the trial court’s denial of Anderson’s petition to seal the record of her eviction case and remands for further proceedings. Holds Indiana Code section 32-31-11-3 required the trial court to seal the eviction record because the landlord moved to dismiss the eviction action after Anderson paid the rent owed and the case was dismissed. Further holds the statute’s use of the word “shall” makes sealing mandatory when the statutory conditions are met, and Anderson satisfied those conditions because the case was dismissed upon the landlord’s motion. Concludes the trial court erred as a matter of law when it denied Anderson’s petition to prohibit disclosure of the eviction records. Judges Altice and Foley concur. Appellant’s attorneys: Megan Stuart; Christopher C. Baumgartner. Appellee’s attorney: none listed.

United States Court of Appeals for the Seventh Circuit
United States of America v. Jerron Williams
No. 24-3173

Criminal. Appeal from the United States District Court for the Northern District of Indiana, Hammond Division, Judge Jon E. DeGuilio. Circuit Judge Kirsch writes that the court dismisses Williams’s appeal from his conviction for assaulting a federal employee and discharging a firearm during a crime of violence after he pleaded guilty. Holds the magistrate judge properly explained the elements of the charged offenses at the change-of-plea hearing and ensured Williams understood the nature of the charges and factual basis for the plea as required by Federal Rule of Criminal Procedure 11 and due process. Further holds the court need not decide whether assaulting a federal employee under 18 U.S.C. § 111(b) qualifies as a “crime of violence” for purposes of 18 U.S.C. § 924(c) because Williams waived that argument multiple times — by pleading guilty, by agreeing to an appeal waiver in his plea agreement and by failing to raise the issue in his motion to withdraw the plea. Concludes the plea was knowing and voluntary and Williams cannot raise a new statutory-interpretation challenge on appeal after repeatedly waiving it. Appellee’s attorneys: Patrick Grindlay, Nicholas J. Padilla. Appellant’s attorney: Thomas William Patton.

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