Billie K. Hoots v. State of Indiana (mem. dec.), 49A04-1611-CR-2539

At ~3:00 a.m. on Sept. 26, 2016, nurse Megan Ridley encountered Billie K. Hoots in the Eskenazi Hospital parking lot after he had been an ED patient earlier that night.
Ridley saw Hoots near her car; frightened by Hoots opening her car door, she left and called hospital security.
Deputy Tony Matthews found Hoots in the lot; Hoots was slow to respond, appeared dazed, and could not remember why he was there; Matthews handcuffed and searched him.
Deputy Zachary Dodson Miranda‑advised Hoots; Hoots stated he had been discharged and had used methamphetamine; Hoots was arrested.
The State charged Hoots with Unauthorized Entry into a Vehicle and Public Intoxication (Class B misdemeanors); the vehicle charge was dismissed on directed verdict, and a jury convicted Hoots of Public Intoxication.
Hoots appealed solely arguing insufficient evidence of intoxication and reliance on his post‑Miranda admission would implicate corpus delecti.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove public intoxication by methamphetamine	State: Deputies' observations and Hoots's admission supported intoxication and that his conduct alarmed Ridley	Hoots: Deputies’ testimony lacked specific signs of meth intoxication; conviction rested on his post‑Miranda admission raising corpus delecti concerns	Affirmed: Deputies’ training‑based observations plus Hoots’s admission provided sufficient independent evidence of intoxication

Sargent v. State, 875 N.E.2d 762 (Ind. Ct. App. 2007) (standards for sufficiency review and intoxication elements under statute)
Woodson v. State, 966 N.E.2d 135 (Ind. Ct. App. 2012) (officer opinion based on training/experience can suffice to show intoxication)
Cox v. State, 774 N.E.2d 1025 (Ind. Ct. App. 2002) (appellate standard: do not reweigh evidence; consider evidence most favorable to judgment)