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).