D.B. v. State of Indiana (mem. dec.), 49A02-1512-JV-2217

Victim S.M. (16) and respondent D.B. (15) were high-school acquaintances and interacted at football practice in August 2015. After practice on August 12, D.B. forced S.M. into sexual contact in a school parking lot; S.M. testified she resisted and later experienced pain and bleeding.
A school custodian observed a sexual act in the parking lot and identified D.B. The next day S.M. reported the incident; a nurse found redness and abrasions consistent with non-consensual sex.
The State filed a juvenile delinquency petition alleging two counts of rape (Level 3 felonies if adult). Following a fact‑finding hearing, the juvenile court found the allegations true and placed D.B. on probation with a suspended commitment.
At trial D.B. testified on direct that he had no prior disciplinary problems at school. On cross‑examination the State impeached him by questioning a 2014 sexual‑harassment suspension allegation involving touching a girl’s private area.
D.B. objected, arguing the prior allegation was unsubstantiated and irrelevant; the juvenile court admitted the impeachment evidence. D.B. appealed, arguing admission was an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by admitting evidence of a prior sexual‑harassment allegation to impeach D.B.	The State argued impeachment was permissible to attack D.B.’s credibility after he testified he had no prior disciplinary issues.	D.B. argued the 2014 allegation was unsubstantiated, irrelevant to the rape charges, and unfairly prejudicial.	Admission was not an abuse of discretion: the evidence was relevant impeachment and its probative value was not substantially outweighed by unfair prejudice.

C.C. v. State, 826 N.E.2d 106 (Ind. Ct. App. 2005) (appellate review of trial court admissibility rulings recognizes broad discretion)
Berry v. State, 967 N.E.2d 87 (Ind. Ct. App. 2012) (abuse‑of‑discretion standard explained)
Konopasek v. State, 946 N.E.2d 23 (Ind. 2011) (Evidence Rule 401 liberal relevancy standard discussed)
Ingram v. State, 715 N.E.2d 405 (Ind. 1999) (Rule 616 must be read with Rule 403 balancing of probative value vs. unfair prejudice)