The Indiana Court of Appeals has overturned a trial court decision mandating that Marquel Jamar Wattley serve his full four-year suspended prison sentence due to probation violations. The appellate court noted that the trial court had not adequately considered the mental health issues Wattley was facing at the time of the violations.

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Wattley was placed on probation in June 2024 as part of his sentence for various felony convictions from 2017, including arson and resisting law enforcement. By March 2025, the Allen County probation department sought to revoke his probation, citing his failure to report for supervision and complete the required treatment. During this period, Wattley was experiencing a mental health crisis linked to his schizophrenia, as highlighted in the court's opinion.

After being deemed incompetent to assist in his defense, Wattley was sent to a behavioral health hospital and regained competency in January. At a status hearing in February, he admitted to violating his probation, but his defense argued that the violations were technical and did not involve any new offenses. Furthermore, it was stated that he was now compliant with medication and would reside with his mother, a former probation officer.

The trial court revoked his probation and denied a motion for reconsideration, citing prior incidents, including battery convictions while in prison, to argue that "no amount of additional community supervision" would lead to compliance with probation and treatment, according to court documents.

The appellate court concurred with Wattley's contention that, since his violations occurred during a documented mental health crisis for which he later received treatment, the punishment should have reflected the nature of his violation rather than other unrelated issues. In prior rulings, the Court of Appeals has maintained that punishments should focus on specific probation violations.

The appellate court acknowledged the trial court's efforts in addressing Wattley’s mental health but agreed that he had not been afforded an opportunity for compliance with probation following his treatment. Consequently, the appellate court reversed the trial court's decision and remanded the case for a new consideration of a punishment more appropriately aligned with Wattley’s compliance post-treatment.

The case is cited as Marquel Jamar Wattley v. State of Indiana, 26A-CR-979.