The Indiana Court of Appeals recently ruled on the case of De'Mario Streeter, who was sentenced for multiple felonies including domestic battery, stalking, and intimidation. The court's decision, filed on October 2, 2026, impacts how sentencing and court costs are handled in similar cases, particularly for defendants claiming indigency.
Streeter, the appellant in this case, pled guilty to a Level 5 felony for domestic battery, a Level 5 felony for stalking, and a Level 6 felony for intimidation. The trial court sentenced him to a total of thirteen-and-a-half years in prison and ordered him to pay court costs and $80 in fees. Streeter argued that the trial court abused its discretion in both the sentencing and the imposition of fees. The court's ruling is significant as it clarifies the standards for sentencing and the financial obligations of defendants.
Background
De'Mario Streeter was charged following a series of violent incidents. On August 28, 2023, he committed domestic battery against his girlfriend, resulting in serious injuries that required surgery. The State of Indiana charged him with a Level 5 felony for domestic battery, which was later amended to include attempted obstruction of justice.
In February 2024, Streeter threatened Detective N.H., a police officer involved in his case, through multiple messages that included violent threats. This led to additional charges of Level 6 felony intimidation. As the case progressed, Streeter was charged with stalking and further intimidation, culminating in a plea agreement in December 2025 where he pled guilty to several charges in exchange for the dismissal of others.
During the sentencing hearing on January 30, 2026, the trial court found Streeter indigent, allowing him to receive services from a public defender. Despite this, the court imposed significant sentences and court costs, which Streeter contested on appeal.
The Ruling
The Indiana Court of Appeals, led by Judge Bradford, reviewed the trial court's decisions regarding sentencing and court costs. The court affirmed the trial court's sentencing decisions, stating, "The trial court acted within its discretion in sentencing Streeter." They noted that the trial court had valid reasons for the sentences imposed, given Streeter's criminal history and the significant harm caused to the victims.
However, the court found that the trial court abused its discretion in ordering Streeter to pay $80 in fees. The ruling stated, "The trial court abused its discretion in imposing the $80.00 jail booking and death benefit fee," as it did not follow the proper legal framework for imposing such fees on an indigent defendant.
Impact
This ruling has implications for how courts handle sentencing and financial obligations for defendants who claim to be indigent. The court affirmed that while a defendant's financial status does not exempt them from all costs, it does require courts to consider their ability to pay. The court emphasized that an indigent defendant cannot be imprisoned for failing to pay court costs.
Moving forward, this case sets a precedent for similar situations where defendants argue against the imposition of fees based on their financial circumstances. It clarifies that courts must conduct thorough inquiries into a defendant's ability to pay before imposing costs and fees, particularly in cases involving serious charges like those faced by Streeter.
What's Next
Streeter's case may still be subject to further legal actions, as the ruling allows for the possibility of appeal regarding the court's decision on the imposition of fees. The court did not specify whether additional related cases are pending, but the implications of this ruling may influence future cases involving indigent defendants in Indiana.