Travis S. Chandler v. State of Indiana

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1258 | October 20, 2026 Page 1 of 7
Pursuant to Indiana Appellate Rule 65(E), the trial court and parties shall not take
any action in reliance upon this memorandum decision until it is certified.
MEMORANDUM DECISION
Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision is not
binding precedent for any court and may be cited only for persuasive value
or to establish res judicata, collateral estoppel, or law of the case.
I N T H E
Court of Appeals of Indiana
Travis S. Chandler,
Appellant-Defendant
v.
State of Indiana,
Appellee-Plaintiff
October 20, 2026
Court of Appeals Case No.
26A-CR-1258
Appeal from the Brown Circuit Court
The Honorable Mary Wertz, Judge
Trial Court Cause No.
07C01-2101-F5-23
Memorandum Decision by Judge Mathias
Judges Pyle and Weissmann concur.

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1258 | October 20, 2026 Page 2 of 7
Mathias, Judge.
[1] Travis Chandler appeals the Brown Circuit Court’s revocation of his probation.
Chandler presents one issue for our review, namely, whether the trial court
abused its discretion when it admitted certain evidence during the hearing on
the State’s petition to revoke his probation.
[2] We affirm.
Facts and Procedural History
[3] On February 5, 2024, Chandler pleaded guilty to Level 5 felony operating a
motor vehicle as a habitual traffic violator. The trial court sentenced him to four
years, with 180 days executed and the balance suspended to probation. The trial
court imposed common conditions of probation, including drug screens and a
prohibition against possessing or using illegal drugs.
[4] From August 12, 2024, through February 6, 2025, Chandler submitted four
drug screens that were positive for methamphetamine. On February 20,
Chandler executed an Administrative Agreement in which he admitted that
those positive drug screens were violations of the terms of his probation. He
agreed to thirty days of day-reporting, and he agreed to attend and complete
moral reconation therapy (“MRT”).1
1 MRT is a program that includes education and counseling.

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1258 | October 20, 2026 Page 3 of 7
[5] On March 19, the State filed a petition to revoke Chandler’s suspended
sentence. In support, the State submitted an affidavit executed by Chandler’s
probation officer stating in relevant part that:
a. [Chandler] provided drug screens on 8/12/24 and 2/6/25.
The toxicologist identified the presence of amphetamine,
methamphetamine, and THC at a level indicative of
methamphetamine and marijuana use while on probation;
b. [Chandler] provided drug screens on 10/3/24, 1/22/25,
2/24/25, 2/27/25 and 3/11/25. The toxicologist identified the
presence of amphetamine and methamphetamine at a level
indicative of methamphetamine use while on probation;
c. [Chandler] failed to report for drug screens as directed on
9/20/24, 11/21/24, 1/16/25, 1/27/25 and 2/6/25;
d. [Chandler] failed to appear for office appointments on
9/30/24, 12/13/24 and 2/11/25;
e. [Chandler] failed to report for day reporting on 2/26/25, to
wit: [Chandler] was placed on day reporting as a result of an
administrative agreement on 2/20/25;
f. [Chandler] has failed to begin MRT as ordered by the Court, to
wit: [Chandler] completed an assessment at Centerstone on
11/20/24 and has failed to complete the program.
Appellant’s App. Vol. 2, p. 59.
[6] At a fact-finding hearing on the petition, the trial court admitted into evidence
the Administrative Agreement and seven positive drug screens, all signed by
Chandler. Chandler admitted that his signature was on the Administrative

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1258 | October 20, 2026 Page 4 of 7
Agreement and two of the drug screen results, but he stated that he did not
recognize the signature on five of the drug screen results.2 The trial court
admitted the proffered exhibits into evidence over Chandler’s objection.
Chandler’s probation officer testified about his missed day-reporting
appointments and missed drug screens as well as his positive drug screens.
Chandler testified that he had not intentionally used methamphetamine. He
testified that he had caught a roommate putting methamphetamine in his coffee
every day.
[7] The trial court found that Chandler had violated the terms of his probation by
using marijuana and methamphetamine/amphetamine; by failing to report for
four drug screens; by failing to report for three office appointments; and by
failing to report for day-reporting on February 26, 2025. Accordingly, the trial
court revoked Chandler’s probation and sentenced him to two years executed.
This appeal ensued.
Discussion and Decision
[8] Chandler contends that the trial court abused its discretion when it admitted
seven drug screen results into evidence during the factfinding hearing. We
review a trial court’s decision to admit or exclude evidence in a probation
revocation proceeding for abuse of discretion. Votra v. State, 121 N.E.3d 1108,
2 The signatures on each of the drug screen results admitted into evidence look substantially similar, and the
trial court found Chandler’s testimony on this issue not credible.

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1258 | October 20, 2026 Page 5 of 7
1113 (Ind. Ct. App. 2019). We will reverse only where the trial court’s decision
is clearly against the logic and effect of the facts and circumstances. Id.
[9] “It is well settled that probationers are not entitled to the full array of
constitutional rights afforded defendants at trial.” Cox v. State, 706 N.E.2d 547,
549 (Ind. 1999). While a probation revocation hearing has certain due process
requirements, it is not to be equated with an adversarial criminal proceeding. Id.
at 549-50. “Rather, it is a narrow inquiry, and its procedures are to be more
flexible.” Id. at 550. This flexibility is necessary to permit the court to exercise
its inherent power to enforce obedience to its lawful orders. Id. And, because of
this flexibility, strict rules of evidence do not apply in probation revocation
hearings. Id.; see also Ind. Evidence Rule 101(d)(2) (providing that rules of
evidence do not apply in proceedings relating to probation). Therefore, in
probation revocation hearings, judges may consider any relevant evidence
bearing some substantial indicia of reliability. Cox, 706 N.E.2d at 551.
[10] On appeal, Chandler argues that the seven drug screen results were inadmissible
under various evidence rules. Chandler acknowledges that, under Indiana
Evidence Rule 101(d)(2), the rules of evidence do not apply to probation
revocation proceedings. But he argues that probation revocation proceedings
are analogous to indirect contempt proceedings, which are subject to the
evidence rules. Chandler urges us to “refer this matter to the Supreme Court
Committee on Rules of Practice and Procedure, serving as the Evidence Rules
Review Committee, for its review and revision of Ind. Evidence Rule 101 to
eliminate the exception of proceedings related to probation from subsection

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1258 | October 20, 2026 Page 6 of 7
(d)(2), should it so choose.” Appellant’s Br. at 17-18. We decline Chandler’s
invitation, although we note that anyone may submit a proposed rule change to
the Rules Committee.3 We hold that the trial court did not abuse its discretion
in the admission of evidence.
[11] The State presented ample evidence bearing sufficient indicia of reliability to
support the revocation of Chandler’s probation. First, in the Administrative
Agreement Chandler executed in February 2025, Chandler admitted to positive
drug screens on August 12, 2024, October 3, 2024, January 22, 2025, and
February 6, 2025. Second, the State presented evidence regarding how the drug
screens were conducted, and each drug screen exhibit included a signed chain
of custody form. Third, the trial court found that Chandler was not credible
when he denied that the signatures on five of the drug screen exhibits were not
his, and our review of the exhibits is consistent with that finding. Chandler has
not shown that the trial court abused its discretion when it admitted the drug
screens into evidence.
[12] In any event, any error in the admission of the drug screens into evidence was
harmless. As the State correctly points out, we will affirm the revocation of
probation where “there is substantial evidence of probative value to support the
trial court’s conclusion that a probationer has violated any condition of
probation.” Murdock v. State, 10 N.E.3d 1265, 1267 (Ind. 2014) (citation
3 See https://www.in.gov/courts/iocs/committees/rules/rule-proposal.

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1258 | October 20, 2026 Page 7 of 7
omitted, emphasis added). Chandler does not challenge the sufficiency of the
evidence regarding his missed appointments, missed drug screens, and missed
day reporting. For all of these reasons, we affirm the trial court’s revocation of
Chandler’s probation.
[13] Affirmed.
Pyle, J., and Weissmann, J., concur.
ATTORNEY FOR APPELLANT
Kurt A. Young
Nashville, Indiana
ATTORNEYS FOR APPELLEE
Theodore E. Rokita
Attorney General of Indiana
Rebekah D. Bennett
Deputy Attorney General
Caroline G. Templeton
Deputy Attorney General
Indianapolis, Indiana