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