Leonard L. Suggs v. State of Indiana
51 N.E.3d 1190
| Ind. | 2016Background
- On Aug. 2, 2014, Leonard L. Suggs and his girlfriend Evelyn Garrett got into a violent altercation at a family reunion; Suggs struck Garrett with a thrown bowling ball (which grazed Garrett and struck Vera Warren) and pulled Garrett down stairs by her hair.
- Warren is the sister of a man who had once been married to Suggs’ aunt; Suggs has known Warren his whole life and calls her "Auntie."
- Children (under 16) witnessed the incident; Warren left and called 911 and later complained of pain from being hit.
- The State charged Suggs with domestic battery (level 6 felony) for the assault on Garrett and battery (level 6 felony) for the assault on Warren, elevating the offense because it was committed against a “family or household member” in the presence of children.
- A jury convicted Suggs on both counts; the trial court imposed consecutive two-year terms (aggregate four years). The Indiana Court of Appeals affirmed; the Indiana Supreme Court granted transfer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Warren was a "family or household member" under I.C. § 35-31.5-2-128, qualifying the battery as a Level 6 felony | State: The statute is broadly written to capture many familial/household relationships; Warren falls within the scope of "related by marriage" and thus is protected | Suggs: Warren is not his blood relative nor directly related by marriage (not a direct in-law); the phrase should be read to cover direct in-laws only, not attenuated relationships | Court: "Related by marriage" means affinity but does not extend to affinity-of-affinity; Warren, being related by blood to a different spouse, is not Suggs’ relative by marriage, so she is not a "family or household member" under the statute; reverse level-6 conviction and remand for conviction as a class A misdemeanor |
Key Cases Cited
- Treadway v. State, 924 N.E.2d 621 (Ind. 2010) (standard for sufficiency-of-the-evidence review)
- Adams v. State, 960 N.E.2d 793 (Ind. 2012) (statutory construction principles: ascertain intent from text)
- Merritt v. State, 829 N.E.2d 472 (Ind. 2005) (construe statutes to avoid absurd results)
- White v. State, 756 N.E.2d 1057 (Ind. Ct. App. 2001) (discussion of affinity and who is related by marriage)
- City of Las Vegas v. Eighth Judicial Dist. Court, 188 P.3d 55 (Nev. 2008) (recognizing that "related by blood or marriage" commonly includes direct in-laws)