Schuyler Stewart v. State of Indiana (mem. dec.)
49A04-1704-CR-727
| Ind. Ct. App. | Sep 13, 2017Background
- On Sept. 13, 2016, Monique Buford drove Schuyler Stewart from his workplace; they argued and stopped at Stewart’s mother’s house.
- Buford testified in a prior recorded statement (admitted at trial as she was unavailable) that Stewart grabbed her keys, jammed them into the ignition, and pulled them out, after which the car would not start and the key would not turn.
- Officer Hasseld observed the car would not start at the mother’s house and saw it towed; Buford’s father later got the car to start by disconnecting/reconnecting the battery.
- Stewart testified (briefly) denying he touched the keys; the State dismissed two battery counts and proceeded on criminal mischief (Class B) for damaging Buford’s vehicle ignition.
- The bench trial court found Stewart guilty of criminal mischief and sentenced him to time served; Stewart appealed arguing insufficient evidence of damage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to convict Stewart of Class B criminal mischief for damaging Buford’s vehicle ignition | Buford’s recorded statement, Officer’s observations, and the tow support a reasonable inference Stewart jammed the keys and caused the ignition/anti-theft to disable the car | No actual damage because Buford’s father later restored operation and no repair to the ignition was paid; Stewart denies touching the keys | Affirmed. Circumstantial and testimonial evidence permitted a reasonable inference of damage; lack of subsequent repair payment does not negate damage or the tow expense |
Key Cases Cited
- Bailey v. State, 979 N.E.2d 133 (Ind. 2012) (appellate standard: do not reweigh evidence or judge witness credibility)
- Drane v. State, 867 N.E.2d 144 (Ind. 2007) (consider only probative evidence and reasonable inferences supporting judgment)
- Harwell v. State, 821 N.E.2d 381 (Ind. Ct. App. 2004) (circumstantial evidence may alone sustain a conviction if it supports a reasonable inference of guilt)
- Gaerte v. State, 808 N.E.2d 164 (Ind. Ct. App. 2004) (circumstantial evidence sufficiency standard)