Angela M. Jewell v. State of Indiana (mem. dec.), 47A01-1610-CR-2330

On May 29, 2016, Officer Anthony Wray observed Angela Jewell (18) and her mother Janice Funk loudly arguing in public; motorists and bystanders stopped to watch.
Wray attempted to investigate and told the women he would listen to Funk first; Jewell repeatedly yelled and interrupted despite multiple requests to stop.
Jewell’s yelling lasted for most of the 10–15 minute encounter (about 20 seconds of quiet), disrupted the officer’s investigation, and caused traffic safety concerns.
After being ordered to sit, Jewell briefly complied, then stood, walked away while still loud, and shouted “I’m fucking done with you,” then continued yelling and banging/kicking the police vehicle after arrest.
Jewell was charged with and convicted following a bench trial of Class B misdemeanor disorderly conduct (Ind. Code § 35-45-1-3(a)(2)) and sentenced to 180 days with 150 days suspended to probation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Jewell knowingly made unreasonable noise and continued after being asked to stop	State: Jewell yelled loudly, disrupted the officer’s investigation, endangered motorists, and ignored repeated orders to be quiet	Jewell: (implicit) her speech was not sufficiently loud/unreasonable to sustain conviction or overcome reasonable doubt	Affirmed — evidence was sufficient to prove unreasonable noise and continuation after being asked to stop

Drane v. State, 867 N.E.2d 144 (Ind. 2007) (standard for sufficiency review and reasonable inferences on appeal)
Barnes v. State, 946 N.E.2d 572 (Ind. 2011) (yelling after warnings can sustain disorderly conduct conviction)
Johnson v. State, 719 N.E.2d 445 (Ind. Ct. App. 1999) (noise unreasonable if too loud for circumstances or disrupts police investigation)