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Rebecca Lawson v. State of Indiana (mem. dec.)
49A05-1603-CR-565
| Ind. Ct. App. | Oct 5, 2016
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Background

  • On Nov. 11, 2015 Rebecca Lawson was charged with one count of criminal mischief (Class B misdemeanor) for slashing the tires on Deborah Hardin’s 1999 Chevy Tahoe.
  • Hardin parked the Tahoe behind her daughter's house around 1:20 a.m.; at ~2:30 a.m. Hardin and her daughter Simone observed Lawson (wearing a dark blue sweatshirt and jeans) and another person near the Tahoe, then saw them run to Lawson’s gray Kia and drive away.
  • All four tires on the Tahoe were found slashed and deflated; no witness directly observed Lawson cutting the tires.
  • Hardin’s son Jason testified that he had broken up with Lawson the day before the incident, establishing possible motive/tension.
  • Following a bench trial the court found Lawson guilty and sentenced her to 180 days (176 suspended); Lawson appealed claiming insufficient evidence because a second person was present.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence to convict Lawson of criminal mischief The State argued circumstantial evidence (presence at scene, flight to car, timing, motive) permits reasonable inference of guilt Lawson argued insufficient proof because another person was present and no one directly saw her slash the tires, creating reasonable doubt Affirmed: circumstantial evidence and reasonable inferences supported conviction beyond a reasonable doubt

Key Cases Cited

  • Suggs v. State, 51 N.E.3d 1190 (Ind. 2016) (standards for reviewing sufficiency and credibility)
  • Horton v. State, 51 N.E.3d 1154 (Ind. 2016) (consideration of probative evidence and reasonable inferences on sufficiency review)
  • Willis v. State, 27 N.E.3d 1065 (Ind. 2015) (requirement that each element be supported by substantial probative evidence)
  • Maxwell v. State, 731 N.E.2d 459 (Ind. Ct. App. 2000) (standard for evaluating circumstantial evidence and permissible inferences)
Read the full case

Case Details

Case Name: Rebecca Lawson v. State of Indiana (mem. dec.)
Court Name: Indiana Court of Appeals
Date Published: Oct 5, 2016
Docket Number: 49A05-1603-CR-565
Court Abbreviation: Ind. Ct. App.