Vakea Johnson v. State of Indiana (mem. dec.)
49A02-1602-CR-337
Ind. Ct. App.Sep 29, 2016Background
- On July 9, 2014, a daycare manager called a meeting to investigate an alleged incident between Amelia Knight and a child. Around six or seven people attended, including Vakea Johnson, her mother (Starks), and sister.
- During the meeting, Knight and Starks got into an altercation; Knight testified Johnson struck her in the face with a closed fist and that fists were "flying everywhere." Knight sustained bruises and scratches to her head, neck, and chest and reported pain.
- Officer Cooper arrived after the fight; Johnson had left the daycare by then. Starks was separately charged but those charges were dismissed.
- The State charged Johnson with Class A misdemeanor battery resulting in bodily injury. At a bench trial Johnson denied being present that day and testified she stayed home.
- The trial court found the State’s witnesses, including Knight, credible, convicted Johnson, and sentenced her to 365 days with part served on home detention and the remainder suspended to probation; additional conditions included anger management and community service.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support Class A misdemeanor battery (bodily injury) | The State: Knight’s testimony that Johnson struck her with a closed fist and caused bruises/pain proves knowing touching and bodily injury. | Johnson: Her testimony denying presence at the daycare creates reasonable doubt and undermines the State’s case. | Affirmed. Court held Knight’s uncorroborated testimony was sufficient and the trial court’s credibility findings resolve conflicts. |
Key Cases Cited
- Bowman v. State, 51 N.E.3d 1174 (Ind. 2016) (appellate deference to trial court outcome on sufficiency review)
- Drane v. State, 867 N.E.2d 144 (Ind. 2007) (consider only probative evidence and reasonable inferences favoring the verdict)
- Jenkins v. State, 726 N.E.2d 268 (Ind. 2000) (affirm conviction unless no reasonable factfinder could find elements proven beyond a reasonable doubt)
- Wright v. State, 828 N.E.2d 904 (Ind. 2005) (appellate courts do not reweigh evidence or reassess witness credibility)
- Lay v. State, 933 N.E.2d 38 (Ind. Ct. App. 2010) (a conviction may rest on the uncorroborated testimony of a single witness)