Larry D. Knox v. State of Indiana
13 N.E.3d 899
Ind. Ct. App.2014Background
- On December 4, 2012, Larry D. Knox encountered a cat inside his home, kicked it multiple times, and one kick knocked out an upper left canine tooth.
- Knox admitted he disliked cats, had no injuries from the cat, and joked about how far the tooth flew.
- Animal Control Officer Miller and animal-care staff observed blood, the detached tooth, and a non‑feral, docile cat with signs of head injury.
- Veterinarians’ x‑rays and testimony showed injuries consistent with a forceful kick while the cat was sitting or crouched; the tooth’s removal required substantial force.
- The State charged Knox with torturing or mutilating a vertebrate animal (Class D felony); Knox claimed he kicked to ward off an alleged attack.
- Following a bench trial, the court found Knox guilty and sentenced him to one year in the Department of Correction; Knox appealed claiming insufficient evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to prove Knox knowingly or intentionally mutilated the cat | State: Knox’s admissions, the severity and nature of injuries, and surrounding facts support an inference of intent/knowledge | Knox: He acted to prevent injury — an affirmative defense that he reasonably believed force was necessary | Court: Evidence was sufficient; intent/knowledge may be inferred from conduct and circumstances; the self‑defense belief was not shown reasonable and depended on Knox’s credibility, which the factfinder rejected |
Key Cases Cited
- Jones v. State, 783 N.E.2d 1132 (Ind. 2003) (standard for sufficiency review and reliance on probative evidence and reasonable inferences)
- E.H. v. State, 764 N.E.2d 681 (Ind. Ct. App. 2002) (intent may be inferred from conduct and its natural sequence)
- Hightower v. State, 866 N.E.2d 356 (Ind. Ct. App. 2007) (definitions and treatment of intentional and knowing conduct under Indiana law)
