Drakkar R. Willis v. State of Indiana
2015 Ind. LEXIS 231
| Ind. | 2015Background
- Willis was charged Jan 28, 2013 with Class A misdemeanor criminal trespass in Marion County.
- Bench trial on Sept 16, 2013 resulted in a conviction and 365 days in jail with 45 days suspended to probation.
- Police responded to the Watkins Family Recreation Center after an alarm activation and reports of voices inside.
- Willis was seen running in a field about 100 yards west of the building; he did not appear to exit the building.
- The center closes at 8 p.m. on Fridays; after-hours access is restricted to property managers or police.
- Indiana Court of Appeals affirmed; the Supreme Court granted transfer and reversed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for trespass | Willis did not interfere with center possession; not proven inside building. | Circumstantial evidence and inferences can prove interference with property use. | Insufficient evidence to sustain conviction |
| Presence at the scene as indicia of guilt | Presence near the center supports guilt of trespass. | Mere presence at or near a crime scene is not enough to prove guilt. | Not enough to convict; requires additional circumstances |
| Flight or evasion as sole proof of guilt | Flight evidence supports inferential guilt. | Flight alone does not prove guilt; may arise from fear or innocence. | Flight is not sufficient by itself to prove guilt |
Key Cases Cited
- Moore v. State, 652 N.E.2d 53 (Ind. 1995) (conviction may be based purely on circumstantial evidence)
- Pratt v. State, 744 N.E.2d 434 (Ind. 2001) (presence at the scene alone is insufficient)
- Dill v. State, 741 N.E.2d 1230 (Ind. 2001) (flight instruction error; flight alone not controlling)
- Maul v. State, 731 N.E.2d 438 (Ind. 2000) (presence with other circumstances may raise inference of guilt)
- Meehan v. State, 7 N.E.3d 255 (Ind. 2014) (sufficiency standard: consider evidence supporting conviction including inferences)
- Vasquez v. State, 741 N.E.2d 1214 (Ind. 2001) (inference cannot be based on uncertain or speculative evidence)