Clayton Labarr v. State of Indiana (mem. dec.)
2015 Ind. App. LEXIS 678
| Ind. Ct. App. | 2015Background
- Labarr was convicted of Class B misdemeanor public intoxication after an incident July 12, 2014 outside Brothers Bar in Indianapolis.
- Officer Randy Weitzel found Labarr unconscious in a taxi minivan and forcibly removed him from the vehicle.
- Labarr was unbelted, unable to sit or stand, and later collapsed on the curb; he vomited and was transported to hospital.
- The trial court convicted Labarr after a bench trial on October 16, 2014, sentencing 180 days suspended with 48 hours of community service.
- On appeal, Labarr argues the evidence does not prove he endangered his own life; the issue is whether the State proved the required elements beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the evidence prove Labarr endangered his own life? | State argues evidence shows Labarr unconscious and exposed on a busy street. | Labarr contends there is insufficient evidence of endangerment. | Yes; evidence supports a reasonable inference Labarr endangered himself. |
Key Cases Cited
- Thang v. State, 10 N.E.3d 1256 (Ind. 2014) (inferences may prove elements; probative evidence required to support conclusions)
- Sesay v. State, 5 N.E.3d 478 (Ind. Ct. App. 2014) (distinguishes when defendant stands nearby but not on a busy road)
- Davis v. State, 13 N.E.3d 500 (Ind. Ct. App. 2014) (stumbles outside, no evidence of road exposure)
- McClellan v. State, 13 N.E.3d 546 (Ind. Ct. App. 2014) (standard for sufficiency review; do not reweigh credibility)