Walter Lyles v. State of Indiana
970 N.E.2d 140
| Ind. | 2012Background
- Walter Lyles, an account holder, was arrested in a bank for Criminal Trespass after being asked to leave.
- Bank policy refused a free print-out and offered a $6 statement instead; Lyles became irate and refused to depart.
- Bank manager asked him to leave; police responded and arrested him after multiple refusals to leave.
- Ind. Code § 35-43-2-2(a)(2) criminalizes trespass by a person not having a contractual interest who refuses to leave after being asked.
- The trial court convicted Lyles of misdemeanor Criminal Trespass; Court of Appeals reversed; State granted transfer and the Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence shows a lack of contractual interest | Ly les | Ly les | Evidence supported lack of contractual interest; conviction affirmed |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (due process requires proof of elements beyond a reasonable doubt)
- Adkins v. State, 887 N.E.2d 934 (Ind. 2008) (elements must be proven beyond reasonable doubt)
- Fleck v. State, 508 N.E.2d 539 (Ind.1987) (lack-of-interest standard limited to reasonably apparent interests)
- Deal v. State, 140 Ind. 354, 39 N.E. 930 (Ind.1895) (insufficient evidence standard for trespass elements)
- Goodpaster v. State, 273 Ind. 170, 402 N.E.2d 1239 (Ind.1980) (material element of lack of contractual interest must be proven beyond doubt)
- Russell v. State, 50 Ind. 174 (Ind.1875) (elements and exceptions framework for trespass)
- Taylor v. State, 836 N.E.2d 1024 (Ind.Ct.App.2005) (definition of contractual interest in trespass context)