Rodriguez v. State
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The Supreme Court affirmed the judgment of the trial court denying Defendant's petition to modify his sentence on the grounds that it was not authorized to modify the sentence imposed under Defendant's fixed-term plea agreement, holding that the decades-old rule that courts may modify a sentence only if a new sentence would not have violated the terms of the valid plea agreement had the new sentence been originally imposed remained undisturbed.
Defendant petitioned to modify his sentence, arguing that recent changes to the modification statute supported the court's ability to modify his sentence. The State opposed the petition, arguing that courts have no power to modify a sentence once the court has accepted a binding stipulated plea agreement. The trial court agreed and denied Defendant's motion to modify his sentence. The court of appeals reversed, concluding that modification of Defendant's sentence was permissible. The Supreme Court granted transfer and affirmed the judgment of the trial court, holding that the legislature's amendments did not alter the settled law of Pannarale v. State, 638 N.E.2d 1247 (Ind. 1994), and its progeny, and therefore, the trial court properly found that it had no discretion to modify Defendant's sentence because it was bound by the terms of the valid plea agreement.
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