Arlana McDade v. State of Indiana (mem. dec.), 49A02-1610-CR-2294

In the early morning of May 31, 2015, Whitney Rogers was driving in Indianapolis with a passenger when a gold Monte Carlo blocked her car; Rogers identified the car as belonging to Arlana McDade.
McDade and two other women exited the Monte Carlo carrying hard objects described by Rogers as “iron bats” and proceeded to smash out all side and rear windows of Rogers’s car; Rogers and her passenger were inside and Rogers was covered in glass.
During the incident McDade said, “Black told me,” suggesting a motive tied to a romantic rivalry involving a man named Steven Reed (“Black”).
Rogers reported the damage ($1,890) and identified McDade to police as the person who “messed up my car.”
The State charged McDade with Level 6 felony criminal recklessness with a deadly weapon and Class A misdemeanor criminal mischief; following a bench trial the court convicted McDade of Class A misdemeanor criminal recklessness and entered judgment under the misdemeanor provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved use of a "deadly weapon" when McDade’s group smashed car windows	State: objects used were metal/iron bats or bars that, as used, were readily capable of causing serious bodily injury	McDade: victim could not identify the objects with certainty (it was dark), so the State failed to prove a deadly weapon	Court: Sufficient — objects were hard enough to shatter windows and could reasonably be inferred to cause serious injury, satisfying the statutory deadly-weapon definition
Whether evidence proved McDade participated in or aided the vandalism	State: McDade’s car blocked Rogers, McDade approached with two women who smashed windows, and McDade’s statement implicated motive; this supports direct or accomplice liability	McDade: Rogers’ testimony did not explicitly state McDade personally struck the windows	Court: Sufficient — even if McDade did not personally swing a bat, her presence, actions, and statement permit an inference she aided/induced the offense; accomplice liability applies

Sallee v. State, 51 N.E.3d 130 (Ind. 2016) (standard for reviewing sufficiency of evidence and inferences to support conviction)
Drane v. State, 867 N.E.2d 144 (Ind. 2007) (evidence sufficient where reasonable inference supports verdict)
Timm v. State, 644 N.E.2d 1235 (Ind. 1994) (blunt objects can be "deadly weapons")
Corder v. State, 467 N.E.2d 409 (Ind. 1984) (baseball bat held to be a "deadly weapon")
Taylor v. State, 840 N.E.2d 324 (Ind. 2006) (a defendant may be convicted as a principal based on proof they aided or induced the offense)