2. Background and Summary of the Opinion
Early notice and unsuccessful safeguards
Judge Salinas took office in January 2007 and, during the relevant period, presided over a misdemeanor and Level 6 felony criminal docket. In December 2021, he reported that a defendant had been improperly detained for 166 days because court staff failed to enter a release code into the case-management system.
Beginning in March 2022, Salinas and other judicial officers developed uniform procedures intended to prevent similar errors. Implementation began that July. Despite those safeguards, serious problems continued.
Continuing release errors
In April 2025, Salinas set a $300 cash bond, but the minute sheet was unclear and staff failed to enter the code needed for the defendant to post bond. Another judicial officer identified the problem in May; the necessary correction and release order followed.
In another case, inconsistent records and an omitted release code prevented implementation of release conditions established on May 19, 2025. The defendant remained in custody until June 9. Salinas reported both incidents himself.
Missing records and neglected criminal cases
In December 2025, the Commission identified thirty cases with missing chronological case summary entries, orders, or future court dates. Salinas subsequently identified ten more. Some deficiencies dated to 2015.
The consequences were substantial:
- A decision reportedly terminating a defendant from Drug Treatment Court in December 2021 was not recorded, and the corresponding arrest warrant was not issued until December 2025.
- A canceled April 2023 initial hearing was not rescheduled until December 2025. The State dismissed the case because the defendant had not been timely tried under Criminal Rule 4(C).
- A bench trial canceled in March 2020 was followed by nearly six years without further action. That prosecution was also dismissed.
Five cases were dismissed under Criminal Rule 4(C). Approximately fifteen additional cases were dismissed after the State declined prosecution or for other unstated reasons. The opinion does not attribute every additional dismissal to a speedy-trial violation.
Expungement failures
The investigation also revealed failures to process expungements. In October 2025, the Marion County Public Defender Agency identified thirteen cases that should have received automatic expungements, with delays ranging from 81 to 795 days. Salinas requested a broader list of pending Superior Court expungements, which contained 427 cases, and directed staff to review them. He did not verify that the necessary work was completed. By December 31, the original thirteen cases remained unexpunged.
A separate incident illustrated the practical consequences of inaccurate records. Salinas granted C.G.’s petition to expunge two criminal cases in 2019, but staff updated only one. In April 2026, an officer relied on the mistakenly unexpunged case as the predicate for charging C.G. with unlawful possession of a firearm by a serious violent felon. C.G. remained detained from April 18 to April 20, when staff corrected the record.
Competency proceedings and amended judgments
Salinas also failed to complete required competency procedures. In one prosecution, he agreed that an examination was appropriate but did not issue the necessary order. No competency hearing followed, despite repeated court appearances over seven months. The defendant was ultimately convicted of sexual battery.
In another matter, staff failed to distribute a competency evaluation received on October 6, 2025. Defense counsel discovered the omission on October 23. Salinas found the defendant incompetent on October 27 and referred him to the Department of Mental Health. The defendant escaped before placement and was later arrested and charged with escape. The opinion recounts that sequence without expressly finding that the report-handling failure caused the escape.
Finally, fifteen cases lacked amended judgments required by agreed alternative misdemeanor sentences. In two cases, amended judgments were not entered until March 2026, although the defendants had successfully completed probation in 2021.
The disposition
The Court found violations of four provisions of the Indiana Code of Judicial Conduct and approved the agreed forty-five-day unpaid suspension. It emphasized both the serious harm caused by the failures and their continuation despite earlier intervention.
The suspension begins at 12:01 a.m. on December 7, 2026, and ends with automatic reinstatement at 12:01 a.m. on January 21, 2027. Costs were assessed against Salinas, and the discipline terminates proceedings concerning the circumstances addressed in the case.
3. Analysis
A. Precedents Cited
Matter of Freese, 123 N.E.3d 683, 688 (Ind. 2019)
The Court cited Matter of Freese when describing a forty-five-day suspension as “just shy of what might warrant removal from office.” The quotation places the sanction near the severe end of the disciplinary spectrum and underscores that Salinas’s misconduct was not treated as a collection of minor clerical mistakes.
The opinion does not describe the underlying facts of Matter of Freese. Its role here is therefore principally to characterize the sanction’s seriousness, not to establish factual equivalence. Nor does the quotation create a fixed rule that any greater suspension necessarily requires removal.
Matter of Norrick, 233 N.E.3d 403 (Ind. 2024)
Matter of Norrick supplied a more direct sanction comparison. That case imposed a forty-five-day unpaid suspension for misconduct that included inadequate staff supervision.
The citation supports treating serious supervisory failures as grounds for substantial suspension. It also confirms that staff-related misconduct is a recognized judicial-disciplinary concern. The Court did not suggest, however, that every supervisory lapse automatically warrants forty-five days; the sanction remained tied to the overall circumstances.
Matter of Brown, 4 N.E.3d 619, 630 (Ind. 2014)
The Court used Matter of Brown as a contrast. Removal was warranted there because the case involved forty-six proven counts of misconduct, mismanagement, delay, and dereliction of duties, together with an “unwillingness or inability” to remedy deficiencies.
That comparison identifies a critical distinction: serious past failures must be assessed alongside the judge’s demonstrated capacity to correct them. Salinas’s eventual adoption of concrete monitoring measures helped distinguish his case from one in which continued judicial service was incompatible with effective administration.
The distinction does not excuse the earlier failures. Rather, it explains why the Court considered suspension sufficient despite misconduct that approached removal-level seriousness.
In re Kouros, 816 N.E.2d 21, 31 (Ind. 2004)
In re Kouros supplied the opinion’s governing account of judicial discipline. Such proceedings do more than punish wrongdoing: they assess fitness for judicial duty, restore public confidence, and preserve judicial integrity and independence.
This framework explains why the Court considered both past harm and present corrective action. Salinas’s cooperation, lack of prior discipline, and implemented reforms mattered because the sanction had to protect the judicial system prospectively, not merely express condemnation retrospectively.
B. Legal Reasoning
Judicial responsibility includes effective administration
Salinas agreed that his conduct violated the following rules:
| Rule |
Duty |
Application |
| Rule 1.1 |
Comply with the law and the Code of Judicial Conduct. |
Required judicial actions, including expungement and competency procedures, were not properly completed. |
| Rule 1.2 |
Promote public confidence and avoid impropriety and its appearance. |
Wrongful detention, inaccurate records, and neglected cases undermined confidence in judicial administration. |
| Rule 2.5(A) |
Perform judicial and administrative duties competently, diligently, and promptly. |
Cases remained inactive, records incomplete, and necessary orders unentered for prolonged periods. |
| Rule 2.12(A) |
Require staff and others under judicial direction to act consistently with judicial ethical obligations. |
Persistent staff errors were not met with sufficiently effective supervision, verification, and timely training. |
The Court treated these duties as interconnected. A judge cannot adequately administer a court by announcing decisions while failing to ensure that the records and processes needed to implement them function reliably.
Delegation requires supervision and follow-through
Many immediate errors were committed by staff. Nevertheless, the Court imposed responsibility on Salinas for inadequate supervision and his own failures to act. The expungement backlog illustrates the distinction between assigning work and ensuring its completion: directing staff to review cases was insufficient when the judge did not follow up and known deficiencies persisted.
The opinion does not establish strict liability for every employee mistake. Its reasoning concerns repeated, serious failures, prolonged notice, ineffective safeguards, delayed training, and inadequate verification.
Procedural omissions can cause substantive harm
The decision rejects any sharp separation between “administrative” errors and meaningful legal injury. An omitted release code can prolong incarceration. A missing expungement entry can cause law enforcement to rely on an inaccurate criminal record. An unscheduled hearing can contribute to dismissal of a prosecution.
The Court expressly found that the misconduct adversely affected litigants and victims and was prejudicial to the administration of justice. This broader perspective recognizes that court dysfunction can injure defendants while also frustrating lawful prosecution and victims’ interests.
Statutory obligations made timely action essential
Indiana Code § 35-38-9-1(b), as discussed in the opinion, provides for automatic expungement in specified circumstances, including dismissal of all charges, acquittal of all charges, and vacatur of a conviction. The quoted provision generally prevents an order from taking effect earlier than sixty days after the relevant disposition. A delay of up to one year requires a prosecutor’s motion and findings of specific justifying facts.
Importantly, the sixty-day language is not described as a universal filing deadline. The disciplinary conclusion rests on the acknowledged failure to complete expungements required in the identified cases, not simply on the fact that sixty days had passed.
Indiana Code § 35-36-3-1(a) likewise requires the court immediately to set a competency hearing when reasonable grounds exist to question whether a defendant can understand the proceedings and assist in preparing a defense. Informal agreement that a defendant should speak with a doctor did not complete the necessary process.
This disciplinary decision did not resolve whether the resulting criminal conviction was invalid or determine any separate appellate or post-conviction remedy.
Repeated notice increased the seriousness of the misconduct
The persistence of problems after the 2021 detention incident and the 2022 reforms was particularly troubling. The Court emphasized that the Commission had worked with Salinas and the criminal courts for years, yet the errors continued. Training was also delayed despite notice of ongoing deficiencies.
Accordingly, the sanction addressed more than isolated mistakes: it responded to an enduring failure to establish reliable corrective controls.
Concrete reforms supported suspension rather than removal
The Court nevertheless credited Salinas’s self-reporting, full cooperation, lack of prior discipline, and remedial efforts. His new measures included:
- A dashboard identifying whether active cases have future court dates;
- Daily lists of expungement-eligible cases;
- Monthly lists of felonies eligible for misdemeanor treatment;
- Daily inmate-list reviews and weekly competency-request reviews; and
- Additional staff training.
These measures supported the conclusion that he had not demonstrated unfitness requiring a longer suspension or removal. They mitigated the sanction without eliminating accountability for past harm.
C. Judicial Disagreement
Chief Justice Rush and Justices Massa, Goff, and Molter concurred. Justice Slaughter concurred in part and dissented in part because he considered the sanction too lenient. The supplied opinion provides no further explanation of his position, so it does not support attributing a particular alternative sanction or additional rationale to him.
D. Potential Impact
The opinion provides practical guidance for future disciplinary cases involving court administration. Persistent backlogs, incomplete records, and unimplemented orders may establish ethical violations when they reflect deficient judicial diligence or supervision.
It also makes clear that corrective action must be operational, not merely aspirational. Written procedures and instructions carry limited mitigating weight when errors continue unchecked. By contrast, recurring reviews, exception reports, and verified completion mechanisms can demonstrate an ability to remedy deficiencies.
For sanction analysis, the decision supplies a significant comparison point: extensive administrative misconduct may warrant a substantial unpaid suspension even when the judge self-reports and cooperates. At the same time, credible reforms may distinguish suspension from removal.
These implications remain context-dependent. The opinion creates neither a mandatory forty-five-day sanction nor a universal requirement that every court adopt the particular software tools used here.