T.C. v. State of Indiana (mem. dec.), 32A01-1606-JV-1318

T.C. is a juvenile who, with K.V., engaged in escalating inappropriate contact starting in autumn 2015 when K.V. was 13 and in seventh grade and T.C. was 15 and a high school freshman.
K.V. testified that T.C. touched her breasts and that the touching made her uncomfortable; she told him to stop.
Dec. 1–2, 2015: K.V. waited at her bus stop; T.C. approached and touched her breasts, attempted to touch her leggings, and penetrated her anus with his penis during a sequence captured partially on surveillance video.
K.V. repeatedly told T.C. to stop and tried to push his hands away; the video quality did not conclusively show all contact, but corroborating testimony supported her account.
The State filed a delinquency petition alleging sexual battery, a Level 6 felony if committed by an adult; the trial court found the allegations true and adjudicated T.C. delinquent.
T.C. appeals, arguing the State failed to prove force or threat of force as required to constitute sexual battery under Indiana law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved force or the threat of force to compel submission	K.V. testified she told T.C. to stop and struggled to push him away	T.C. argues no force or coercion was proven	Yes, sufficient evidence of force/compulsion as perceived by K.V.

Tobias v. State, 666 N.E.2d 68 (Ind. 1996) (victim's perspective governs force assessment; subjective compulsion)
Bailey v. State, 764 N.E.2d 728 (Ind. Ct. App. 2002) (prior refusals and subsequent assault show compulsion)
Frazier v. State, 988 N.E.2d 1257 (Ind. Ct. App. 2013) (force may be implied from circumstances)
Z.A. v. State, 13 N.E.3d 438 (Ind. Ct. App. 2014) (reaffirmed sufficiency standard for delinquency adjudication)