Indiana Court of Appeals Case No. 16A01‑1010‑CR‑544 (Sneed v. State, 2011) centers on whether the trial court abused its discretion by (1) setting $25,000 cash‑only bail and (2) refusing to allow the defendant, Melissa Sneed, to post a surety bond. The appellate court held that the amount of bail was permissible, but the cash‑only requirement was improper, so it affirmed in part, reversed in part, and remanded.

⚖️ Core outcome

  • Bail amount ($25,000): Not excessive given the seriousness of two Class A felony meth‑dealing charges.
  • Cash‑only restriction: Abuse of discretion because Indiana law requires courts to consider multiple bail forms, including surety bonds.
  • Result: Affirmed in part, reversed in part, and remanded for the trial court to allow a surety‑bond option.

🔍 Key facts the court relied on

  • Sneed had strong community ties, including long‑term residence in Indiana and three children living with her.
  • She had no violent criminal history, only two prior misdemeanors, and had never failed to appear in court.
  • She had no income or assets, making cash‑only bail functionally unattainable.
  • The State presented no evidence opposing her request for a surety‑bond option, relying only on the seriousness of the charges.

🧠 Legal analysis

The appellate court applied Indiana’s bail statutes, which give trial courts discretion over bail amounts, but require them to consider multiple permissible forms of bail. A court may choose among cash deposit, 10% deposit, or surety bond, but it must exercise that discretion reasonably.

  • The amount was upheld because Class A felony meth‑dealing carries severe penalties, and the bail was not “clearly excessive.”
  • The cash‑only requirement was struck down because the trial court gave no reasoning, ignored statutory alternatives, and effectively punished Sneed pretrial by denying a realistic path to release.

📌 Why this case matters

This decision reinforces that Indiana courts may set high bail for serious offenses, but they cannot impose cash‑only bail without justification. Bail must balance public safety, flight risk, and statutory options—not serve as a de facto detention order.