Criminal Law

Meth Bust Driver Fails to Overturn Meth Possession Conviction or 12-Year Sentence

Meth Bust Driver Fails to Overturn Meth Possession Conviction or 12-Year Sentence

Representative image for illustration purposes only

The Indiana Court of Appeals has upheld the conviction and sentence of Taylor D. Hunt, who was found unconscious at a stoplight with a handgun and baggies of suspected methamphetamine. Hunt had challenged the sufficiency of the evidence supporting his conviction for possession of methamphetamine and argued that his 12-year sentence was excessive. The appellate court affirmed the trial court’s rulings on both counts.

The Stop and Discovery

The case stems from an incident on August 22, 2023, when Fort Wayne Police Sergeant David Klein noticed Hunt’s vehicle stopped at the intersection of Coldwater Road and Cook Road. Hunt’s brake lights were engaged, and he failed to move through the intersection for several light cycles.

Upon approaching the vehicle, Sergeant Klein found Hunt unconscious in the driver’s seat, leaning back. The officer also observed what appeared to be a hand-rolled joint on Hunt’s waistband. Concerned that startling the unconscious driver could cause an accident, Klein attempted to reach through an open rear window to put the car in park and secure the keys. As he reached in, the vehicle began rolling forward.

After Klein shouted police commands, Hunt suddenly woke up and stopped the car. Once Hunt was conscious, he informed the officers that he was carrying a handgun, which Klein subsequently removed from his waistband. A further search revealed two plastic bags containing multicolored tablets in Hunt’s pocket. Hunt reportedly told officers the tablets were ecstasy but admitted they would test positive for methamphetamine. A records check also showed Hunt was on parole for a robbery conviction.

The Charges and Conviction

The State charged Hunt with possession of methamphetamine as a Level 3 felony and unlawful possession of a firearm by a serious violent felon (a Level 4 felony). At a bench trial before the Allen Superior Court, Judge Steven O. Godfrey found Hunt guilty of the methamphetamine possession charge, though the opinion notes the trial court entered a conviction only on that count. Hunt was sentenced to 12 years of incarceration.

Challenging the Evidence: The Methamphetamine Weight Issue

On appeal, Hunt’s primary challenge to his conviction centered on the weight requirement for the Level 3 felony charge of possession of methamphetamine. To secure this conviction, the State needed to prove Hunt knowingly possessed between 10 and 28 grams of the drug, along with an applicable enhancing circumstance.

Hunt argued that the evidence was insufficient because only one tablet from one of the two bags seized (State’s Exhibit 5) was tested. That single tested tablet weighed only 0.28 grams.

The Court of Appeals, in an opinion authored by Judge Felix, rejected this argument, emphasizing that they do not reweigh the evidence. The court noted that the forensic scientist tested one tablet from Exhibit 5, which contained numerous multicolored tablets all marked with an “F” symbol. The trial court was entitled to infer that the remaining untested tablets in that bag were also methamphetamine.

Crucially, the court relied on precedent allowing for the testing of a representative sample. This inference was strengthened by Hunt’s own admission to officers that the tablets would test positive for methamphetamine. Given that the tested pill was methamphetamine and all pills in the bag shared the same marking, the appellate court found there was sufficient evidence for a reasonable fact-finder to conclude Hunt possessed at least 10 grams of the controlled substance.

Reviewing the 12-Year Sentence

Hunt also sought a sentence reduction under Indiana Appellate Rule 7(B), arguing his 12-year sentence was inappropriate given the nature of the offense and his character. The statutory range for a Level 3 felony is three to 16 years, with an advisory sentence of nine years. Hunt requested his sentence be reduced to nine years executed or 12 years with three suspended to probation.

The Court of Appeals reviews sentencing claims with deference to the trial court, noting that sentence revision is reserved for “exceptional” cases. The court analyzed two main prongs: the nature of the offense and the character of the offender.

Regarding the nature of the offense, the court highlighted the dangerous circumstances of the arrest. Hunt was passed out while driving, with the car in gear, creating a hazard for others on the road. While Hunt cooperated after being awakened, the court found his actions leading up to the stop “illustrate[d] no restraint or regard for his fellow motorists.” The court also noted that while he possessed two bags of alleged meth, he was only convicted based on one.

Turning to the character of the offender, the court examined Hunt’s history. His presentence investigation report revealed two prior misdemeanors and two prior felonies. Furthermore, the instant offense occurred while he was on parole, and he had multiple instances of revoked probation. The report also flagged his long-standing affiliation with the “Gangster Disciples” gang.

The court concluded that Hunt had failed to produce “compelling evidence” showing that his sentence was inappropriate based on either prong. His history suggested a rejection of prior reform opportunities. Therefore, the 12-year sentence was affirmed as not inappropriate under Rule 7(B).

The appellate court ultimately affirmed the trial court’s judgment on all issues raised.

Case Information

Case Name:
Taylor D. Hunt v. State of Indiana

Court:
Court of Appeals of Indiana

Judge:
Judge Felix (Opinion Author)