Leonard L. Suggs v. State of Indiana
31 N.E.3d 998
Ind. Ct. App.2015Background
- On Aug. 2, 2014, Leonard L. Suggs and his long‑term live‑in girlfriend Evelyn Garrett attended a family reunion at a bowling alley where many children were present.
- An altercation occurred: Suggs yelled at Garrett, threw a beer can (missed), then threw a bowling ball that grazed Garrett and struck Vera Warren in the head.
- Suggs then jumped on Garrett and pulled her by the hair down stairs, causing significant pain; children at the event witnessed the violence.
- Warren called 911; police interviewed Garrett and two children who were panicked by what they saw.
- The State charged Suggs with two Level 6 felonies: domestic battery (against Garrett) and battery (against Warren).
- A jury convicted Suggs of both counts; the trial court imposed consecutive two‑year terms (total four years). Suggs appealed, arguing insufficient evidence for both convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency to prove “living as spouse” for Level 6 domestic battery | State: Suggs and Garrett cohabited, shared a bedroom, had a two‑year ongoing romantic relationship — meets statutory factors | Suggs: Cohabitation and intimacy alone are insufficient to show living as spouses | Court: Evidence of two‑year cohabitation, shared bedroom, and ongoing romantic relationship is sufficient; affirms conviction |
| Sufficiency to prove Warren was a “family or household member” for Level 6 battery | State: Warren is related to Suggs by marriage (Suggs’s aunt married Warren’s brother) and functionally treated as family (Suggs called her “Auntie,” she attended family reunion) | Suggs: Relationship is too attenuated to qualify as family/household member | Court: Statutory definition is broad; marital relation plus familial practice suffices; affirms conviction |
Key Cases Cited
- Williams v. State, 798 N.E.2d 457 (Ind. Ct. App. 2003) (cohabiting, ongoing romantic relationship supports domestic‑battery status of living as spouses)
- Bowling v. State, 995 N.E.2d 715 (Ind. Ct. App. 2013) (domestic battery statute contemplates ongoing cohabiting relationships)
- McClellan v. State, 13 N.E.3d 546 (Ind. Ct. App. 2014) (standard for reviewing sufficiency of evidence: do not reweigh evidence or judge credibility)