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Wayne Tashwn Kelly v. State of Indiana

2026-08-31

Summary

Holding. The Court of Appeals reversed Kelly's conviction for unlawful possession of a firearm by a serious violent felon and remanded the case to vacate the conviction and sentence on that count, holding that the Illinois burglary statute is not substantially similar to Indiana's burglary-of-a-dwelling statute and therefore Kelly does not qualify as a serious violent felon.

Wayne Kelly was convicted of unlawful possession of a firearm by a serious violent felon and resisting law enforcement after police found a handgun with his DNA and fingerprints during a traffic stop that escalated into a high-speed chase. The State based the firearm conviction on a prior 2009 Illinois burglary conviction, claiming it made Kelly a serious violent felon under Indiana law.

The Court of Appeals reversed Kelly's firearm conviction, holding that the Illinois burglary statute under which Kelly was convicted is not substantially similar to Indiana's burglary-of-a-dwelling statute. The Illinois burglary statute applies to entry into various structures including buildings, watercraft, aircraft, and railroad cars without requiring that the structure be a dwelling. In contrast, Indiana's burglary-of-a-dwelling offense—the only level of burglary that qualifies as a serious violent felony—specifically requires the building to be a dwelling place. The court rejected the State's argument that Kelly's underlying conduct of entering a dwelling could supply the missing element, finding that what matters is the offense to which Kelly pleaded guilty: the base burglary offense that requires only entry into a building, not a dwelling.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether an out-of-state burglary statute is substantially similar to Indiana's burglary-of-a-dwelling statute for purposes of qualifying as a serious violent felon
  • How to apply the substantial similarity test when comparing broader out-of-state statutes to narrower Indiana predicate offenses
  • Whether courts may look beyond the statutory elements to the underlying conduct when comparing foreign and Indiana statutes

Procedural posture

Kelly appealed his conviction following a bench trial in Lake Superior Court, raising a sufficiency-of-evidence challenge to the firearm conviction based on whether he qualified as a serious violent felon.

Authorities cited

Opinion

majority opinion

FILED

Aug 31 2026, 9:25 am

CLERK

Indiana Supreme Court

Court of Appeals

and Tax Court

IN THE

Court of Appeals of Indiana

Wayne T. Kelly,

Appellant-Defendant

v.

State of Indiana,

Appellee-Plaintiff

August 31, 2026

Court of Appeals Case No.

26A-CR-665

Appeal from the Lake Superior Court

The Honorable Samuel L. Cappas, Judge

Trial Court Cause No.

45G04-2111-F4-205

Opinion by Chief Judge Tavitas

Judges Bradford and Felix concur.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 1 of 17

Tavitas, Chief Judge.

Case Summary

[1] Following a bench trial, Wayne Kelly was convicted of unlawful possession of

a firearm by a serious violent felon, a Level 4 felony, and resisting law

enforcement, a Level 6 felony. On appeal, Kelly claims that the evidence is

insufficient to support his conviction for unlawful possession of a firearm by a

serious violent felon. We agree and, accordingly, reverse and remand.

Issue

[2] Kelly presents two issues, one of which we find dispositive and restate as:

whether the State presented sufficient evidence to prove that Kelly was a serious

violent felon.1

Facts

[3] On November 1, 2021, Indiana State Police Trooper Elias Espinoza was

patrolling on Interstate 65 in Lake County when he observed a black Chevrolet

Camaro approach his vehicle from behind and pass him at a high speed.

Trooper Espinoza activated his emergency lights and pulled the Camaro over.

When he approached the car, Trooper Espinoza saw three people inside: Kelly,

who was the driver, Lauren Taylor, who was seated in the front passenger seat,

1

Because we conclude that there was insufficient evidence to prove that Kelly was a serious violent felon, we

need not address his argument that there was also insufficient evidence to prove that he actually or

constructively possessed a firearm.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 2 of 17

and Terrel Holt, who was in the back seat. Kelly admitted that he was

speeding, but when asked for his driver’s license, Kelly stated that he did not

have it in his possession at the time. Trooper Espinoza noticed that Holt was

not wearing a seatbelt. Trooper Espinoza also smelled the odor of marijuana

emanating from the car. Kelly admitted that he had smoked marijuana earlier

that day but denied the presence of guns or drugs in the car when asked.

[4] When Trooper Espinoza returned to his patrol vehicle to run a records search,

Kelly began to move around inside the car and leaned over into the passenger

seat. A black handgun was then tossed from the passenger’s side window,

landing in the ditch beside the road. Kelly drove off, leading the police on a

high-speed chase. Eventually, Kelly collided with two other vehicles and

crashed into a median ditch. The two passengers remained at the scene of the

crash, but Kelly fled the scene and was apprehended shortly thereafter. The

police located the handgun that had been tossed from the car and took

fingerprints and DNA swabs from Kelly. Subsequent testing revealed the

presence of Kelly’s DNA and fingerprints on the weapon.

[5] Kelly’s fingerprints linked him to two prior convictions in Illinois: in 2009,

Kelly was convicted of Class 3 felony theft and Class 2 felony burglary; and in

2015, Kelly was convicted of Class 4 felony aggravated fleeing from law

enforcement. The certified records of the 2009 burglary conviction indicated

that Illinois had initially indicted Kelly for Class 1 felony residential burglary

based on his entry into the dwelling place of another. The original indictment

identified the victim by name and gave her street address, including a unit

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 3 of 17

number. Pursuant to a plea agreement, the indictment was amended to Class 2

felony burglary, and Kelly pleaded guilty as charged to the amended

indictment. The amendment substituted the word “building” for “dwelling” in

the burglary count but retained the victim’s address. Ex. Vol. I p. 46.

[6] On November 2, 2021, the State charged Kelly with: Count I, unlawful

possession of a firearm by a serious violent felon, a Level 4 felony; Count II,

resisting law enforcement, a Level 6 felony; Count III, leaving the scene of an

accident causing bodily injury, a Class A misdemeanor; Count IV, resisting law

enforcement, a Class A misdemeanor; and Count V, leaving the scene of an

accident, a Class B misdemeanor. A bench trial was held on October 9, 2025,

at the conclusion of which the trial court found Kelly guilty on Counts I and II

but not guilty on the remaining counts. At a February 13, 2026 sentencing

hearing, the trial court imposed an aggregate sentence of ten years. Kelly now

appeals.

Discussion and Decision

[7] Kelly claims that the State failed to prove that he was a serious violent felon. 2

Kelly does not deny the facts underlying his current convictions. Nor does he

deny that he has a prior conviction in Illinois. 3 But he claims that his 2009

2

Kelly does not challenge his conviction for resisting law enforcement.

3

In its summary of the argument, the State claims that Kelly’s 2015 Illinois conviction for Class 4 felony

aggravated fleeing from law enforcement is substantially similar to Level 5 felony resisting law enforcement

in Indiana, which is a serious violent felony. See Ind. Code § 35-47-4-5(b)(18)(B). We note that the State

alleged only the Illinois burglary conviction as the predicate serious violent felony. See Appellant’s App. Vol.

II p. 18. The State, moreover, does not further develop this claim in the argument section of its brief; the

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 4 of 17

Illinois conviction for burglary is not substantially similar to the Indiana crime

of burglary of a dwelling, a conviction for which would render Kelly a serious

violent felon. This is a question of law we review de novo. Moore v. State, 49

N.E.3d 1095, 1104 (Ind. Ct. App. 2016). We keep in mind that “criminal

statutes must be strictly construed against the State, and ‘may not be enlarged

beyond the fair meaning of the language used . . . .” A.-H.Y. v. State, 975

N.E.2d 1273, 1279 (Ind. 2012) (quoting Bond v. State, 515 N.E.2d 856, 857-58

(Ind. 1987)). Also, “[when] general and specific statutes conflict in their

application to a particular subject matter, the specific statute will prevail over

the general statute.” Snider v. State, 753 N.E.2d 721, 723 (Ind. Ct. App. 2001),

trans. denied.

A. The Serious Violent Felon Statute

[8] “A serious violent felon who knowingly or intentionally possesses a firearm

commits unlawful possession of a firearm by a serious violent felon, a Level 4

felony.” Ind. Code § 35-47-4-5(c). A serious violent felon is defined as “a

person who has been convicted of committing a serious violent felony.” I.C. §

35-47-4-5(a). A serious violent felony is defined to include:

burglary (IC 35-43-2-1) as a:

State does not identify the Illinois statute under which Kelly was convicted for fleeing from law enforcement,

nor does it compare the elements of that offense with the Indiana offense of resisting law enforcement as a

Level 5 felony. This argument is, therefore, waived. See Ind. Appellate Rule 46(A)(8)(a) (requiring appellate

arguments to be supported by cogent reasoning). Accordingly, we address only that predicate offense.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 5 of 17

(A) Class A felony or Class B felony, for a crime committed

before July 1, 2014; or

(B) Level 1 felony, Level 2 felony, Level 3 felony, or Level 4

felony, for a crime committed after June 30, 2014[.]

I.C. § 35-47-4-5(b)(16).

[9] “Indiana appellate courts have held that a person may qualify as [a serious

violent felon] based on felony convictions from another jurisdiction so long as

the conviction is ‘substantially similar’ to an offense listed in Indiana Code

[S]ection 35-47-4-5(b).” State v. Johnson, 270 N.E.3d 489, 498 (Ind. Ct. App.

2025) (citing State v. Hancock, 65 N.E.3d 585, 587 (Ind. 2016)), trans. denied.

Prior versions of the serious violent felon statute directly included the

“substantially similar” language, but that provision has since been moved to

Indiana Code Section 1-1-2-4. Johnson, 270 N.E.3d at 498 n.1; see also State v.

Gomez, No. 25S-CR-14, slip op. at 8 (Ind. June 30, 2026) (“Whenever [a]

predicate offense statute makes a reference to a conviction for an Indiana

criminal offense, it becomes subject to Indiana Code [S]ection 1-1-2-4, ‘the

reference statute.’”), reh’g pending.

[10] This “reference statute” provides in relevant part:

Except as provided in subsection (c),[ 4] a reference to a conviction

for an Indiana criminal offense appearing within the Indiana

Code also includes a conviction for any of the following:

4

The parties appear to agree that subsection (c) is inapplicable here.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 6 of 17

*****

(3) A substantially similar offense committed in another

jurisdiction, including an attempt or conspiracy to commit the

offense, even if the reference to the conviction for the Indiana

criminal offense specifically refers to an “Indiana conviction” or

a conviction “in Indiana” or under “Indiana law” or “laws of this

state”.

I.C. § 1-1-2-4(b) (emphasis added).

[11] Our trial courts have the unenviable task of comparing foreign statutes to

Indiana statutes to determine whether offenses are substantially similar. 5 To

determine whether an offense in another jurisdiction is substantially similar to

an Indiana offense, we must compare the foreign statute under which the

defendant was convicted with the Indiana statute at the time of the current,

Indiana offense. Moore, 49 N.E.3d at 1104; see also State v. Akins, 824 N.E.2d

676, 678 (Ind. 2005) (“The correct comparison is between the Michigan statute

under which the defendant was convicted and the Indiana statute at the time of

the Indiana offense.”).

The Indiana Code does not define “substantially similar,” but in

State v. Bazan, 45 N.E.3d 856, 859 (Ind. Ct. App. 2015), we held

5

At trial here, the State made conclusory statements that Kelly was a serious violent felon based on his 2009

Illinois burglary conviction without comparing the Illinois and Indiana burglary statues. See Tr. Vol. II pp. 5,

88-89. Kelly’s defense counsel simply argued that there was insufficient proof that Kelly was in possession of

the handgun thrown from the car. Id. at 94. But this does not mean that Kelly waived his appellate

argument. It is well settled that “a claim of insufficiency of the evidence can be made for the first time on

appeal.” Williams v. State, 64 N.E.3d 226, 227 (Ind. Ct. App. 2016) (citing Ind. Trial Rule 50(A)(5) (criminal

defendant may challenge sufficiency of evidence at trial, in a motion to correct error, or for the first time on

appeal); see also Collins v. State, 364 N.E.2d 750, 754 (Ind. 1977) (citing Trial Rule 50 in holding that “a

defendant [may] raise sufficiency of the evidence for the first time on appeal.”).

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 7 of 17

that an out-of-state statute was not “substantially similar” to an

Indiana statute when the out-of-state statute was broader than the

Indiana statute. Specifically, we held that a New York statute for

operating a vehicle while impaired was not substantially similar

to Indiana’s statute for operating a vehicle while intoxicated

because the Indiana statute required a greater showing of

impairment. See id. In contrast, where an out-of-state statute was

more stringent than an equivalent Indiana statute, our [S]upreme

[C]ourt held that the statutes were substantially similar. See State

v. Akins, 824 N.E.2d 676 (Ind. 2005) (holding that because

Michigan’s statute for operating a vehicle while being under the

influence of an intoxicating liquor or having an alcohol content

of 0.10 grams or more per 100 milliliters of blood required a

degree of intoxication greater than Indiana’s equivalent statute,

the two statutes were substantially similar).

Moore, 49 N.E.3d at 1104 (some citations omitted). And in Hancock, our

Supreme Court, after considering dictionary definitions of the words

“substantial” and “similar,” held that “the elements of two statutes are

‘substantially similar’ if they have common core characteristics that are largely,

but not identically, alike in degree or extent.” 65 N.E.3d at 587.

B. The Illinois Burglary Statute

[12] At the time Kelly committed his 2009 Illinois offense, 6 the Illinois statute

defining the crime of burglary provided:

(a) A person commits burglary when without authority he

knowingly enters or without authority remains within a

building, housetrailer, watercraft, aircraft, motor vehicle as

6

Kelly was convicted in March 2009 in Illinois of an offense that he committed on January 23, 2009.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 8 of 17

defined in The Illinois Vehicle Code, railroad car, or any part

thereof, with intent to commit therein a felony or theft. This

offense shall not include the offenses set out in Section 4-102 of

The Illinois Vehicle Code.

(b) Sentence.

Burglary is a Class 2 felony. A burglary committed in a school or

place of worship is a Class 1 felony.

720 Ill. Comp. Stat. Ann. 5/19-1 (2001) (emphases added, footnotes omitted).

At the same time, the Illinois offense of residential burglary was defined by a

separate statute as follows:

(a) A person commits residential burglary who knowingly and

without authority enters or knowingly and without authority

remains within the dwelling place of another, or any part

thereof, with the intent to commit therein a felony or theft. This

offense includes the offense of burglary as defined in Section 19-1.

(b) Sentence. Residential burglary is a Class 1 felony.

720 Ill. Comp. Stat. Ann. 5/19-3 (2001) (emphasis added).

[13] Illinois, thus, has defined separate offenses for burglary generally and burglary

of a dwelling specifically. See id. (“This offense includes the offense of burglary

as defined in Section 19-1.”). Illinois’ choice to address dwelling-burglary

through a separate, more specific statute confirms that the omission of a

dwelling requirement from the general burglary statute was deliberate.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 9 of 17 [14] Kelly was originally indicted under the Illinois residential burglary statute. The

indictment alleged that he “knowingly and without authority entered the

dwelling place” of the victim with the intent to commit theft therein. Ex. Vol. I

p. 46. At the plea hearing, however, the Illinois trial court granted the

prosecution leave to amend the bill of indictment by interlineation.

Specifically, the word “dwelling” was marked out and the word “building” was

substituted in its place. Id. The citation to the operative statute was also

changed from the Illinois residential burglary statute to the Illinois burglary

statute. The Illinois trial court then accepted Kelly’s plea to burglary as a Class

2 felony “as charged in” the amended indictment and entered judgment of

conviction accordingly. Id. at 55. It is, therefore, clear that Kelly was convicted

of the base offense of burglary in Illinois, not residential burglary.

C. The Indiana Burglary Statute

[15] The offense of burglary in Indiana is defined 7 as follows:

A person who breaks and enters the building or structure of

another person, with intent to commit a felony or theft in it,

commits burglary, a Level 5 felony. However, the offense is:

(1) a Level 4 felony if the building or structure is a dwelling . . . .

Ind. Code § 35-43-2-1.8

7

We must compare the Illinois burglary statute under which Kelly was convicted with the Indiana statute at

the time of the instant, Indiana offense. Akins, 824 N.E.2d at 678; Moore, 49 N.E.3d at 1104.

8

Notably, both Illinois and Indiana grade burglary as a more serious offense when a dwelling is involved.

This reinforces our conclusion that the dwelling element is what separates the more serious offense from the

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 10 of 17

D. The Offenses Are Not Substantially Similar

[16] Kelly claims that the Illinois offense of burglary is not substantially similar to

the Indiana offense of burglary of a dwelling, a Level 4 felony, which is a

serious violent felony. Accordingly, Kelly argues that he does not qualify as a

serious violent felon and that the evidence is insufficient to sustain his

conviction. We agree.

[17] The Illinois offense of burglary has three elements. In contrast, the Indiana

burglary-of-a-dwelling statute—which elevates the offense to a Level 4 felony

and qualifies as a serious violent felony—requires four elements. The following

chart compares the elements of these statutes:

Illinois Indiana

1. knowingly entering or remaining 1. breaking and entering

within without authority

2. a building, housetrailer, 2. a building or structure of another

watercraft, aircraft, motor vehicle, person

railroad car, or any part thereof

3. with the intent to commit therein a 3. with the intent to commit a felony

felony or theft or theft in it

4. the building or structure is a

dwelling

lesser one in both states. Compare 730 Ill. Comp. Stat. Ann. 5/5-4.5-35 (providing that a Class 2 felony, such

as general burglary, is punishable by three to seven years of imprisonment), and 730 Ill. Comp. Stat. Ann.

5/5-4.5-30 (providing that a Class 1 felony, such as residential burglary, is punishable by four to fifteen years

of imprisonment), with Ind. Code § 35-50-2-6(b) (providing that a Level 5 felony, which includes burglary of a

non-dwelling structure, is punishable by one to six years of imprisonment), and Ind. Code § 35-50-2-5.5

(providing that a Level 4 felony, which includes burglary of a dwelling, is punishable by two to twelve years’

imprisonment).

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 11 of 17

720 Ill. Comp. Stat. Ann. 5/19-1 (2001); Ind. Code § 35-43-2-1(1).

[18] Simply put, the Illinois burglary statute contains no requirement that the

structure at issue be a dwelling. “Dwelling” under Indiana law means “a

building, structure, or other enclosed space, permanent or temporary, movable

or fixed, that is a person’s home or place of lodging.” Ind. Code § 35-31.5-2-107. “[O]ur courts have said that burglary of a dwelling is not so much an

offense against property as it is an offense against the sanctity and security of

habitation.” Howell v. State, 53 N.E.3d 546, 549 (Ind. Ct. App. 2016) (citing

Watt v. State, 446 N.E.2d 644, 645 (Ind. Ct. App. 1983)), trans. denied. The

Illinois burglary statute is indifferent to habitation, and it protects various forms

of property, including those not typically used as dwellings.

[19] We conclude, therefore, that the Illinois burglary statute under which Kelly was

convicted is broader than Indiana’s burglary-of-a-dwelling statute because

conduct violating the Illinois statute would not necessarily constitute burglary

of a dwelling in Indiana. “[A]n out-of-state statute is not substantially similar

to an Indiana statute where the out-of-state statute is broader than the Indiana

statute.” Hancock, 65 N.E.3d at 590.

[20] The State notes that two statutes need not be identically worded to be

substantially similar, so long as they display a “high degree of likeness.” Id. at

587, 590. Although “substantial similarity” does not require identical statutory

language, see id. at 587, the difference here is not merely one of wording. The

Illinois statute reaches conduct the Indiana statute does not reach at all:

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 12 of 17

entering a watercraft, aircraft, motor vehicle, or railroad car is burglary in

Illinois, but it is not burglary of a dwelling in Indiana. Nor is the dwelling

element incidental. Burglary qualifies as a serious violent felony only if it is at

least a Level 4 felony, and—absent bodily injury or a deadly weapon, neither of

which were alleged here—the dwelling requirement is what elevates the offense

to that level in Indiana. I.C. § 35-43-2-1. The element the Illinois statute lacks

is precisely what makes the Indiana offense a serious violent felony. Moreover,

a separate Illinois statute defines the distinct offense of residential burglary—

burglary of a dwelling; and Kelly did not plead guilty to that offense but to the

lesser, base offense of burglary.

[21] The State claims that Hancock permits courts to look beyond the text to consider

the conduct underlying the out-of-state conviction. The State contends that the

charging instrument shows Kelly broke into an apartment, which would qualify

as a dwelling and would, therefore, make the offense burglary as a Level 4

felony, sufficient to render Kelly a serious violent felon. The State’s argument

relies on the portion of the Hancock opinion in which the Court observed that

elements “may be considered substantially similar with respect to specific

characteristics such as the underlying conduct sought to be regulated.” 65

N.E.3d at 587 (emphasis added). We do not read Hancock so broadly.

[22] First, the Court in Hancock referred to the underlying conduct the statute at

issue seeks to regulate, not the specific conduct of the defendant in a particular

case. Id. at 586. Moreover, the Court in Hancock did not base its decision on

what the defendant had done in the out-of-state conviction. In fact, the Court

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 13 of 17

noted that the underlying facts of the out-of-state conviction were not entirely

clear. Id. at 586. The Court then compared the elements of each offense,

considered Ohio’s classification of criminal offenses, and consulted law from

both states to construe the terms of the statutes. Id. at 588. If consideration of

the defendant’s underlying conduct were sufficient, none of the Court’s

discussion of Ohio law would have been necessary. 9 Also, in that case, the

predicate Ohio statute required trespass in an occupied structure maintained as

a permanent or temporary habitation, with another person present or likely

present. Id. at 591-92. The Court found substantial similarity because those

elements aligned with Indiana’s dwelling requirement such that conduct

violating the Ohio statute would necessarily violate Indiana’s burglary-of-adwelling statute. Id. In contrast, here, the Illinois burglary statute can be

violated by entry into several structures, such as a railroad car, which would not

constitute burglary of a dwelling in Indiana.

[23] Much of the State’s argument is based on the original indictment, which alleged

that Kelly entered a dwelling without authorization. But this indictment was

amended before Kelly pleaded guilty, most notably by eliminating the word

“dwelling” and substituting in its place the word “building.” Ex. Vol. I p. 46.

9

The State’s reliance on Spencer v. State, 153 N.E.3d 289 (Ind. Ct. App. 2020), is misplaced. In that case, the

court addressed whether certain Florida offenses were “substantially equivalent” to the Indiana offense of

child molesting. Id. at 296 (quoting Ind. Code § 35-38-1-7.5(b)(1)(K)). But there, neither party disputed how

the Florida offenses compared with their Indiana counterparts, and the court ultimately resolved the case on

the ground that the Florida offenses were committed before the date the Indiana statute required. See id. at

296-98. Even assuming that Spencer permits a court to consider the facts underlying an out-of-state

conviction, we do not read it to allow consideration of an allegation that was struck from the charging

instrument as part of the defendant’s guilty plea.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 14 of 17

The State refers to the rule in Illinois that a voluntary guilty plea admits the

facts of the offense charged. People v. Gonzalez, 259 N.E.3d 288, 294-95 (Ill.

App. Ct. 2025). But what was ultimately charged in Illinois, after the

amendment, was unauthorized entry into a building, not a dwelling. And this

is the offense to which Kelly pleaded guilty and the offense for which he was

convicted. The State also notes that the amended indictment retained the

victim’s street address, which included a unit number. 10 But the mere fact that

the victim’s address included a unit number and that the premises was,

therefore, likely a dwelling does not mean that Kelly pleaded guilty to

residential burglary; to the contrary, he pleaded guilty to the lesser, base offense

of burglary, where entry into a dwelling was not an element of the offense. 11

[24] In short, we conclude that the Illinois burglary statute is not substantially

similar to the Indiana statute defining burglary of a dwelling, a Level 4 felony,

10

The State makes the same argument regarding the theft count of the amended indictment, to which Kelly

also pleaded guilty. This count retained the victim’s name and address and alleged that she owned the

property. But an allegation contained in a separate count is not an element of the burglary offense to which

Kelly pleaded guilty. These details may well establish that the building Kelly entered was, in fact, a dwelling.

But that is not the question; the question is for which offense judgment of conviction was entered. And, here,

the Illinois trial court entered a judgment of conviction for an offense that could be committed by entering

any building. This makes the Illinois offense broader and, therefore, not substantially similar to the Indiana

offense of burglary of a dwelling.

11

The State’s position would lead to absurd results if applied to Indiana law. Imagine a defendant who

breaks and enters a dwelling with the intent to commit a felony therein; this defendant is charged with

burglary of a dwelling, a Level 4 felony, which would make the defendant a serious violent felon if convicted.

But, during plea bargaining, the State agreed to lower the offense to the base offense of burglary, a Level 5

felony. Under the State’s position, a court could look to the defendant’s conduct forming the basis of the

original charge to conclude that the defendant actually committed an offense that would be Level 4 felony

burglary of a dwelling—and that the defendant was, thus, a serious violent felon—even though he pleaded

guilty to the lesser-included base offense of burglary of a structure. The same would be true of an habitual

offender enhancement—it would permit a court to look at the facts underlying the offense and conclude that

the offense committed was, in fact, a felony, even if the defendant was convicted of a misdemeanor. This

would be an untenable result.

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 15 of 17

which is required to qualify burglary as a serious violent felony. Kelly is,

therefore, not a serious violent felon, and we must reverse his conviction for

unlawful possession of a firearm by a serious violent felon.

Conclusion

[25] The Illinois burglary statute under which Kelly was convicted is not

substantially similar to the Indiana statute defining burglary of a dwelling, a

conviction for which would qualify Kelly as a serious violent felon. Kelly is,

thus, not a serious violent felon based on the Illinois conviction. Accordingly,

we reverse Kelly’s conviction for unlawful possession of a firearm by a serious

violent felon and remand to the trial court with instructions to vacate Kelly’s

conviction and sentence on that count.

[26] Reversed and remanded.

Bradford, J., and Felix, J., concur.

ATTORNEY FOR APPELLANT

R. Brian Woodward

Appellate Public Defender

Crown Point, Indiana

ATTORNEYS FOR APPELLEE

Theodore E. Rokita

Attorney General of Indiana

Kelly A. Loy

Section Chief for Criminal Appeals

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 16 of 17 Alexa R. Rojas

Deputy Attorney General

Indianapolis, Indiana

Court of Appeals of Indiana Opinion 26A-CR-665 August 31, 2026 Page 17 of 17