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Published by the Indiana Office of Court Services

Murphy v. State, No. 18S02-1103-CR-142, __ N.E.2d __ (Ind., Mar. 10, 2011)

March 18, 2011 Filed Under: Criminal Tagged With: F. Sullivan, Supreme

SULLIVAN, J.
. . . While in pretrial confinement in the Delaware County Jail awaiting sentencing, Murphy earned his general educational development (“GED”) diploma. At sentencing, the trial court granted Murphy pretrial confinement credit time of 511 days for time served, with Class I credit time of an additional 511 days, for a total of 1,022 days.  [Footnote omitted.]  Murphy also requested that the court grant him six months of educational credit time for receiving his GED.  [Footnote omitted.]  The trial court informed Murphy that he should submit his request for educational credit time to the Department of Correction (“DOC”).  [Footnote omitted.]
On appeal, Murphy contended that the trial court is the proper authority to determine whether a defendant who completes an educational degree before sentencing is entitled to educa-tional credit time. As noted, the trial court thought such determinations are the province of the DOC. For its part, the State contended that such determinations should be made by the jailing authority, in this case the Delaware County Jail.
The Court of Appeals agreed with Murphy and held that the trial court is the proper authority to determine whether a defendant who completes an educational degree before sentencing is entitled to educational credit time. Murphy v. State, 930 N.E.2d 630, 632 (Ind. Ct. App. 2010). Judge Crone, writing for the court, reasoned that:
It is the trial court that initially determines a defendant’s sentence; the trial court determines the amount of credit time to which the defendant is entitled as of the time of his sentencing. While the trial court bases its decision on the jail records, the actual decision is made by the trial court at a hearing with both sides present in a situation where if a dispute arises it can be resolved after input from all concerned. The trial court is also in a better position than the Department of Correction to determine whether educational credit time should be granted for a degree earned prior to sentencing. The defendant did not earn the degree under the supervision of the Department of Correction and any dispute regarding whether or not the prisoner has demonstrated a pattern consistent with rehabilitation would usually need to be resolved with reference to a local facility.
Id. at 632-33 (footnote omitted).
We agree with Judge Crone’s analysis and the result reached by the Court of Appeals. We therefore grant transfer and adopt its opinion in full. Ind. Appellate Rule 58(A)(1).
Shepard, C.J., and Dickson, Rucker, and David, JJ., concur.

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