Baker v. State, 968 N.E.2d 227

Baker challenges the sufficiency of evidence for burglary, arguing no evidence shows intent to commit theft.
On Jan 22, 2008, a church member found a broken window, blood, and pry marks at Harvest Time Tabernacle Church; no items appeared missing.
DNA from the scene matched Baker; parties stipulated Baker was the DNA source.
The State charged burglary of a structure used for religious worship with intent to commit theft and sought habitual offender sentencing.
At trial, Baker was convicted of class B burglary; the Court of Appeals reversed for lack of evidence of theft intent; the Supreme Court granted transfer and affirmed.
The Court reviews sufficiency of evidence by considering the favorable evidence and reasonable inferences, focusing on whether a rational jury could find guilt beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence of felonious intent to steal at entry?	Baker: no such evidence	State: opening cupboards/drawers implies intent to steal	Yes; circumstantial evidence supported a reasonable inference of theft intent

Gilliam v. State, 508 N.E.2d 1270 (Ind. 1987) (necessity of independent proof of felonious intent)
Freshwater v. State, 853 N.E.2d 941 (Ind.2006) (circumstantial evidence suffices; must show specific intent)
Kondrup v. State, 250 Ind. 320, 235 N.E.2d 703 (Ind.1968) (felony-intent may be inferred from circumstances)
Justice v. State, 530 N.E.2d 295 (Ind.1988) (mens rea usually circumstantial; need solid basis for intent)
Kidd v. State, 530 N.E.2d 287 (Ind.1988) (circumstantial evidence can sustain burglary conviction)
Faulkner v. State, 260 Ind. 82, 292 N.E.2d 596 (Ind.1973) (fact-pattern on independent basis for intent; overruled later but relevant to standard)
Lisenko v. State, 265 Ind. 488, 355 N.E.2d 841 (Ind.1976) (early rule on inferred intent from time/manner of entry)
Carter v. State, 265 Ind. 535, 356 N.E.2d 220 (Ind.1976) (abrogated by later decisions; relied on for historical context)