Sanchez Dupree Martin v. State of Indiana (mem. dec.), 71A05-1611-CR-2674

Martin met Adams (digital artist) and worked briefly for pay at Project Impact; Adams later entrusted Martin with a tablet to distribute flyers, which Martin did not return.
On March 22, 2016, Project Impact's alarm activated; police found a broken window beside the door, the door unlocked, and one of Adams’s computers missing.
The broken window had blood; DNA testing showed the blood matched Martin (statistical exclusion all but Martin).
Adams identified Martin in a police lineup; Martin called Adams the morning after the burglary asking about what happened.
Martin was charged with Level 5 felony burglary (I.C. § 35-43-2-1), tried in a bench trial, convicted, and sentenced to six years; he appealed on sufficiency-of-the-evidence grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence Martin committed burglary?	State: Evidence (broken window, unlocked door, missing computer, Martin's DNA on glass, ID in lineup, phone call) supports conviction	Martin: At most shows presence/opportunity; no direct proof of intent to steal	Yes. Court affirmed: facts and DNA supported inference he broke in and entered
Was there sufficient evidence of intent to commit theft?	State: Theft occurred (missing $2000 computer) contemporaneous with break-in; this, plus other facts, shows intent	Martin: No evidence he intended to steal; could be investigating instead	Yes. Court held the simultaneous theft and break-in sufficiently established intent

Cox v. State, 774 N.E.2d 1025 (Ind. Ct. App. 2002) (standard for reviewing sufficiency of the evidence)
Sargent v. State, 875 N.E.2d 762 (Ind. Ct. App. 2007) (application of sufficiency review principles)
McMahel v. State, 609 N.E.2d 1175 (Ind. Ct. App. 1993) (reversal where defendant shown only to be in wrong place at wrong time)
Freshwater v. State, 853 N.E.2d 941 (Ind. 2006) (breaking-and-entering must be tied to corroborative evidence of intent to commit felony)