Stephani Merrell v. State of Indiana (mem. dec.), 49A04-1604-CR-710

On July 30, 2015, an Indianapolis police sergeant stopped Stephani Merrell’s Honda CRV because its load of wooden pallets was unsecured and pieces of cardboard were flying into traffic.
Sergeant Tuchek approached, identified himself, and requested Merrell’s driver’s license and vehicle registration.
Merrell repeatedly did not comply: she manipulated her phone, claimed to be recording, discussed medical issues, and refused to give name or date of birth despite multiple requests and a warning of arrest.
After repeated refusals (the officer asked six to ten times), backup arrived, Merrell was ordered out of the car, placed in custody, and officers found her license in a purse in the vehicle.
The State charged Merrell with refusal to provide identification (Class C misdemeanor). A jury found her guilty and she appealed, challenging sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Merrell knowingly/ intentionally refused to provide identification to an officer who stopped her for an infraction	State: Officer lawfully stopped vehicle for unsafe load; repeated requests for name/DOB/license were refused; identity not learned until custody — sufficient for conviction	Merrell: She looked for her purse/license, gave license number and DOB which officer ignored, and was medically unable (asthma attack) to comply	Court affirmed: viewing evidence in favor of verdict, reasonable trier of fact could find she knowingly/ intentionally refused to provide identification

Delagrange v. State, 5 N.E.3d 354 (Ind. 2014) (standard for sufficiency review — do not reweigh evidence or reassess witness credibility)
Griesemer v. State, 26 N.E.3d 606 (Ind. 2015) (sufficiency standard — consider evidence most favorable to verdict)
Johnson v. State, 933 N.E.2d 544 (Ind. Ct. App. 2010) (upholding conviction where defendant refused repeated identification requests during traffic stop)