Anthony Roberson v. State of Indiana (mem. dec.), 49A02-1612-CR-2761

On Dec. 27, 2015, Govindbhai Patel, a Gujarati-speaking motel employee, discovered Anthony Roberson sleeping in a vacant room, found him hiding in the bathroom, and testified Roberson pushed him, causing a back injury.
Patel and motel staff pursued Roberson; police arrested Roberson nearby.
State charged Roberson with Class A misdemeanor battery (resulting in bodily injury) and criminal trespass; bench trial was held.
The court used a court-appointed interpreter, Depak Goradia, to translate Patel’s Gujarati testimony into English; Roberson repeatedly objected to the manner (summarizing vs. literal translation).
The trial judge admonished the interpreter to translate verbatim, acknowledged Roberson’s standing objection, and stated the court would give the testimony appropriate weight; Roberson did not object to the interpreter’s qualifications at trial.
The court found Roberson guilty of Class A misdemeanor battery, sentenced him to jail (with much suspended) and probation, and ordered no contact/stay-away provisions; Roberson appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Roberson)	Held
Qualification of interpreter / admission of translated testimony	Interpreter was acceptable; translated testimony admissible	Trial court failed to adequately inquire into interpreter’s qualifications; translation manner was improper	Waiver: Roberson did not object to qualifications at trial; no fundamental error found in allowing Goradia to translate
Manner of interpretation (summarizing vs. verbatim) / potential prejudice	Any translation irregularity could be considered and given appropriate weight by bench	Interpreter summarized witness’ answers, creating prejudicial distortion of testimony	Bench trial context: court admonished interpreter and said it would give proper weight; no fundamental error because judge presumed to disregard any inadmissible or unreliable parts
Sufficiency of the evidence for battery	Evidence (Patel’s testimony) supports that Roberson knowingly touched Patel in a rude/angry manner causing bodily injury	Patel’s testimony was inconsistent/vague and did not prove rude/angry touching beyond a reasonable doubt	Evidence sufficient: inferences from Patel’s testimony supported conviction; appellate court will not reweigh or reassess credibility

Griffin v. State, 698 N.E.2d 1261 (Ind. Ct. App. 1998) (presumption that trial court in bench trial disregards inadmissible testimony)
James v. State, 613 N.E.2d 15 (Ind. 1993) (definition of fundamental error as blatant violation of basic principles)
Madden v. State, 656 N.E.2d 524 (Ind. Ct. App. 1995) (fundamental error permits review of waived issues when denial of fair trial is apparent)
Drane v. State, 867 N.E.2d 144 (Ind. 2007) (standard for sufficiency review; appellate courts do not assess witness credibility)
Walker v. State, 998 N.E.2d 724 (Ind. 2013) (sufficiency review—view evidence in light most favorable to verdict)
Cruz Angeles v. State, 751 N.E.2d 790 (Ind. Ct. App. 2001) (suggested topics a trial court may ask to qualify an interpreter)