Cathy Byrd v. State of Indiana (mem. dec.), 49A05-1610-CR-2358

Defendant Cathy Byrd confronted her ex-husband Warren Morphis and his then-girlfriend Thelma Thomas outside Morphis’ house late on June 9, 2015; Byrd parked next to Thomas’ parked car in the driveway and yelled insults at Thomas through a window.
Byrd attempted to enter Morphis’ house by removing a window screen but could not get inside; Morphis went to retrieve his phone to call police.
When Morphis returned, he saw Byrd standing between her car and Thomas’ car; Byrd then drove away.
After Byrd left, Morphis and Thomas discovered scratches on the driver’s side and trunk of Thomas’ 2006 Chevrolet Cobalt; Thomas later paid a $250 deductible and insurance covered the rest of approximately $1,200–$1,300 in repair costs.
Byrd was charged with Class A misdemeanor criminal mischief (damage between $750 and $50,000). Following a bench trial, the court found Byrd guilty, sentenced her to two days jail (time served), and ordered $250 restitution. Byrd appealed, arguing insufficient evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Byrd)	Held
Whether evidence was sufficient to prove Byrd caused the damage to Thomas’ car	Circumstantial evidence (Byrd’s presence, conduct, proximity to car, prior confrontation, and her statement "I don’t know" when asked) supports an inference Byrd scratched the car	No eyewitness tied Byrd to scratching and presence alone is insufficient	Court: Sufficient — circumstantial evidence supported a reasonable inference of guilt
Whether evidence established pecuniary loss ≥ $750	Thomas testified repair cost was about $1,200–$1,300; State presented no contrary evidence	Byrd argued amount not proven beyond reasonable doubt	Court: Sufficient — victim’s unrebutted testimony was enough to meet statutory threshold

Maul v. State, 731 N.E.2d 438 (Ind. 2000) (circumstantial evidence alone can support a conviction if it permits a reasonable inference of guilt)
Willis v. State, 27 N.E.3d 1065 (Ind. 2015) (presence at scene plus other conduct can support inference of participation)
Hitch v. State, 51 N.E.3d 216 (Ind. 2016) (standard of review for bench trial judgments: deference to trial court credibility findings)
Oney v. State, 993 N.E.2d 157 (Ind. 2013) (review principles under clearly erroneous standard)
Womack v. State, 738 N.E.2d 320 (Ind. Ct. App. 2000) (victim testimony on repair cost can satisfy damage threshold)
Mitchell v. State, 559 N.E.2d 313 (Ind. Ct. App. 1990) (once statutory damage threshold is met, exact amount is immaterial)