Christopher Smith v. State of Indiana
2014 Ind. LEXIS 257
| Ind. | 2014Background
- G.G. is a 16-year-old CHINS ward at YOC in Muncie; she reported a rape at Muncie Central to school staff.
- Smith, the Muncie Central principal, did not report the alleged rape to DCS or police for about four hours.
- Staff actions included nurse Anderson, assistant principal McCord, and other administrators handling the report, interviewing S.M., and reviewing lockers.
- The YOC was engaged for G.G.’s care, and several district officials advised on reporting and investigations during the day.
- Officer Edwards and later detectives investigated; S.M. confessed later; Smith faced a criminal charge for failure to report under Ind. Code § 31-33-22-1(a).
- Smith was convicted after a bench trial; Court of Appeals reversed, then Indiana Supreme Court granted transfer and affirmed conviction, rejecting vagueness and sufficiency challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the reporting statute is unconstitutionally vague as applied | Smith argues ‘immediately’ is vague and should be read with a 24-hour boundary. | State contends ordinary understanding of ‘immediately’ is urgent reporting and not unconstitutional as applied. | Not vague; ‘immediately’ interpreted with urgency; four-hour delay violates duty. |
| Was the evidence sufficient that Smith had reason to believe G.G. was a child abuse victim | Smith contends staff believed minor-on-minor rape isn’t child abuse; cannot prove reason to believe. | State argues rape is a CHINS predicate, and Smith’s conduct shows reason to believe. | Sufficient evidence that Smith had reason to believe; rape is a CHINS predicate and he acted with belief. |
| Whether Smith failed to report immediately | Smith asserts reporting to YOC or DCS within minutes complies with immediacy. | YOC is not an independent recipient; reporting to DCS within hours is not immediate. | Phone call to YOC did not satisfy the obligation; reporting four hours later was not immediate; conviction upheld. |
| Whether the statute's scope was incorrectly interpreted to require court-ordered CHINS status for reporting | Smith argues reliance on CHINS status is a defense to reporting duty. | Statutes require reporting when there is reason to believe abuse occurred, regardless of CHINS status as later amended. | Court held CHINS status knowledge informs, but statute requires immediate reporting upon reasonable belief; Smith failed. |
Key Cases Cited
- Brown v. State, 868 N.E.2d 464 (Ind. 2007) (vagueness review defers to statutory clarity and ordinary understanding)
- Downey v. State, 476 N.E.2d 121 (Ind. 1985) (limits of vagueness in statutory provisions)
- Anonymous Hosp. v. A.K., 920 N.E.2d 704 (Ind. Ct. App. 2010) (time-of-report phrasing indicating urgency in reporting statutes)
- Klein v. State, 698 N.E.2d 296 (Ind. 1998) (statutory language informing generally proscribed conduct)