Miguel Casas v. State of Indiana

26A-CR-01334Indctapp21 oct. 2026

Texte intégral

Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 1 of 9
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not binding precedent for any court and may be cited only for persuasive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
Miguel Casas,
Appellant-Defendant
v.
State of Indiana,
Appellee-Plaintiff
October 21, 2026
Court of Appeals Case No.
26A-CR-1334
Appeal from the Warren Circuit Court
The Honorable Hunter J. Reece, Judge
Trial Court Cause No.
86C01-2506-F1-140
Memorandum Decision by Judge Altice
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 2 of 9
Judges Bailey and Bradford concur.
Altice, Judge.
Case Summary
[1] 	Without the benefit of a plea agreement, Miguel Casas pleaded guilty as
charged to two counts of Level 1 felony child molesting, two counts of Level 4
felony child molesting, and four counts of Level 4 felony child exploitation. His
victims were a two-year-old and a six-year-old girl. The trial court sentenced
him to an aggregate term of ninety-six years, with sixteen years suspended to
probation. Casas appeals, arguing that the trial court abused its discretion with
respect to the consideration of mitigating circumstances.
[2] 	We affirm.
Facts & Procedural History
[3] 	In April 2025, the Indiana State Police (ISP) assisted in an investigation of
CyberTips received by the National Center for Missing and Exploited Children.
The CyberTips files contained photos and videos of sexual acts between an
adult male and juvenile victims that were produced between 2018 and 2019.
The adult male was identified as Casas.
[4] 	During the subsequent investigation, which included searches of a hard drive
stored under Casas’s bed in a gun box, his Google account, and his cell phones,
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 3 of 9
investigators determined that numerous images depicted crimes that occurred in
both Warren County and Tippecanoe County. This case involves crimes that
occurred in Warren County in 2019 against Victim 1, a two-year-old girl, and
Victim 2, a six-year-old girl. The investigation also revealed other victims, both
identified and unidentified, and thousands of pornographic images of teenage
and prepubescent girls, as well as concerning pictures secretly taken of women
in public.
[5] 	In June 2025, the State charged Casas, as amended, with eight counts: two
counts of Level 1 felony child molesting (Counts 1 and 2); four counts of Level
4 felony child exploitation (Counts 3, 4, 6, and 8); and two counts of Level 4
felony child molesting (Counts 5 and 7). The first four counts involved Victim 1
and the last four involved Victim 2.1
[6] 	At the final pretrial hearing on April 7, 2026, two weeks before the scheduled
jury trial, Casas pleaded guilty as charged without the benefit of a plea
agreement. The sentencing hearing was held on April 21, 2026, at which ISP
Trooper Jonathan Fulfer testified in detail regarding the investigation and the
digital evidence discovered. Trooper Fulfer testified that four child victims had
been identified so far, and many images depicting Casas’s crimes against the
children were admitted into evidence.
1 In February 2026, the State charged Casas in Tippecanoe County under Cause No. 79D01-2602-F1-5 with
fifteen counts, including three counts of Level 1 felony child molesting involving Victim 1 and Victim 1’s
four-year-old cousin. That case remains pending.
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 4 of 9
[7] 	The presentence investigation report (PSI) showed that Casas had a prior
misdemeanor conviction for driving while suspended. Casas reported to the
probation officer that he had used many illegal drugs, including daily
methamphetamine use through 2021, and claimed that he was high on drugs,
experienced blackouts, and did not remember his crimes. Aside from pleading
guilty, he did not take any responsibility for his crimes, and he did not
acknowledge the seriousness of them. Casas told the probation officer, “I didn’t
kill anyone” and “the kids don’t remember.” Appendix at 100. When asked what
sentence someone with his crimes should receive, Casas responded: “Maybe a
couple years and strict parole to watch what I do. I’ve suggested castration, but
I found out that is illegal.” Id. at 102. Casas did not take the opportunity to
speak at sentencing, instead presenting the testimony of two family members
and his girlfriend to speak to his character.
[8] 	When sentencing Casas, the trial court found a number of aggravating
circumstances: Victim 1 and Victim 2 were of tender ages, two and six years
old, which made the crimes “particularly heinous”; Casas violated a position of
trust and had care, custody, or control over them; he committed a crime of
violence in the presence of another child who was not the victim; and he has a
criminal history, including a misdemeanor driving offense in 2018, uncharged
criminal acts addressed at sentencing, and the related charges that were pending
in Tippecanoe County. Transcript at 51. In mitigation, the court found that
Casas “entered an open plea of guilty with no benefit what so ever, [] which
saved further [] victimization of the victims and their families and all of those
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 5 of 9
that would have to observe it and substantially limited his appellate rights.” Id.
at 52.
[9] 	The trial court also observed that Casas met the definition of a “sexually violent
predator” both statutorily and by the specific facts of the case. Id. The court
explained:
[M]any of the images testified to by the trooper [and] observed by
the Court[, e]ven those not arising to the level of criminal
conduct[,] are troublesome and they demonstrate the mental
issue that is a danger to our community, whenever he may be at
large. Uh, the Court also considers the graphic nature of the acts
that occurred and the voluminous amount of those to photograph
and video tape uh, child molesting that you are committing so
that you can [relive] that over and over again. Uh, demonstrates
a concern to the Court to protect children in our communities
those who are the most tender and lack the ability to even report
their victimization.
Id. at 52-53. Given that Casas would be a credit restricted felon, the court
recognized that he would be required to serve a substantial portion of the
sentence imposed “on top of his already thirty (30) years of age.” Id. at 53.
[10] 	The court then sentenced Casas to forty years each for Counts 1 and 2, the
Level 1 felonies, and eight years each on Counts 3-8, the Level 4 felonies. The
court ordered a combination of concurrent and consecutive sentences, making
the child molesting counts – Counts 1, 2, 5, and 7 – consecutive to each other
and the child exploitation counts – Counts 3, 4, 6, and 8 – concurrent with the
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 6 of 9
child molesting counts. This resulted in a sentence of ninety-six years, of which
the trial court suspended sixteen years to probation.
[11] 	Casas now appeals his sentence. Additional information will be provided below
as needed.
Discussion & Decision
[12] 	Casas argues that the trial court abused its sentencing discretion. He does not
challenge any of the aggravating circumstances found by the trial court. Rather,
he argues that the trial court “failed to place a sufficient weight upon the fact
that Casas, potentially facing an extraordinary amount of jail time, pled ‘open’
without the benefit of a previously negotiated deal.” Appellant’s Brief at 13
(emphasis added). According to Casas, the trial court “should have recognized
[the] great risk he was taking” along with the benefits to the victims and the
State in avoiding trial and thus “afforded him more credit.” Id. at 14 (emphasis
added). Casas also asserts that he was thirty years of age at the time of
sentencing and thus “[h]is young age would show that he is likely to respond
affirmatively to probation or short-term imprisonment and could be
rehabilitated.” Id.
[13] 	It is well established that sentencing decisions are within the sound discretion of
the trial court. Owen v. State, 210 N.E.3d 256, 269 (Ind. 2023). “An abuse of
discretion occurs if the decision is clearly against the logic and effect of the facts
and circumstances before the court, or the reasonable, probable, and actual
deductions to be drawn therefrom.” Id. (internal quotations omitted). A trial
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 7 of 9
court has no obligation to “weigh” aggravating and mitigating factors when
imposing a sentence, and thus it cannot be said to have abused its discretion in
failing to “properly weigh” such factors. Anglemyer v. State, 868 N.E.2d 482, 491
(Ind. 2007), clarified on reh’g, 875 N.E.2d 218; see also Baumholser v. State, 62
N.E.3d 411, 416 (Ind. Ct. App. 2016) (“We review for an abuse of discretion
the court’s finding of aggravators and mitigators to justify a sentence, but we
cannot review the relative weight assigned to those factors.”).
[14] 	One way in which a trial court may abuse its discretion is by omitting
mitigating factors that are clearly supported by the record and advanced for
consideration. Anglemyer, 868 N.E.2d at 491. It is not enough to show that the
trial court failed to address the significance of a mitigating factor advanced by
the defense, as a trial court is not obligated to explain why it has found the
factor not to exist. Id. at 493. “An allegation that the trial court failed to identify
or find a mitigating factor requires the defendant to establish that the mitigating
evidence is both significant and clearly supported by the record.” Id. (emphasis
added).
[15] 	Casas’s primary argument on appeal is that the trial court failed to give
adequate weight to the mitigating circumstances surrounding his guilty plea.
But this claim is unavailable for review. The trial court found the guilty plea to
be a mitigating circumstance and noted that Casas received no benefit for the
plea and that the plea saved the victims and their families from being further
victimized at trial. Casas asked the trial court to give his guilty plea substantial
weight, but a trial court is “not required to give the same weight to proffered
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 8 of 9
mitigating factors as does a defendant.” Smoots v. State, 172 N.E.3d 1279, 1288
(Ind. Ct. App. 2021). In sum, the trial court clearly considered this mitigating
circumstance, and it cannot be found to have abused its discretion with respect
to weight it gave the guilty plea. See Baumholser, 62 N.E.3d at 416.
[16] 	Finally, regarding the claim that his “young age” should have been considered
mitigating, we observe that Casas does not direct us to any authority to support
the proposition that thirty years old is an age deserving of mitigating treatment.
Moreover, he did not advance this as a mitigating circumstance below, so he
cannot do so now on appeal. See Fisher v. State, 264 N.E.3d 696, 707 (Ind. Ct.
App. 2025) (“Generally, if the defendant fails to advance a mitigating
circumstance at sentencing, the court will presume that the factor is not
significant, and the defendant is precluded from advancing it as a mitigating
circumstance for the first time on appeal.”) (internal quotations omitted).
[17] 	Judgment affirmed.
Bailey, J. and Bradford, J., concur.
ATTORNEY FOR APPELLANT
Justin R. Wall
Huntington, Indiana
ATTORNEYS FOR APPELLEE
Theodore E. Rokita
Indiana Attorney General
Court of Appeals of Indiana | Memorandum Decision 26A-CR-1334 | October 21, 2026 	Page 9 of 9
Robert M. Yoke
Deputy Attorney General
Indianapolis, Indiana

Poursuivez vos recherches dans ChatGPT ou Claude

Connectez Omnilex pour rechercher dans le corpus juridique depuis votre assistant IA.