Woodson v. State
966 N.E.2d 135
| Ind. Ct. App. | 2012Background
- Police responded to report of a man and woman fighting; found Woodson and a woman on a sidewalk.
- Officer Chapman smelled alcohol on Woodson; Woodson was abrasive and slurred his speech.
- Woodson admitted to consuming a pint of liquor and a 32-ounce beer.
- Woodson refused to remove his hands from his pockets after repeated requests, leading to handcuffing and arrest.
- Woodson was charged with Class B misdemeanor public intoxication in Marion Superior Court.
- Motion to suppress the evidence from the encounter was denied; bench trial held; Woodson convicted; appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of evidence from encounter challenged | Woodson argues no reasonable suspicion. | State contends encounter was consensual until odor/impaired speech. | Evidence admissible; encounter became a Terry stop when odor observed. |
| Sufficiency of evidence for intoxication | Insufficient proof of impairment. | Evidence showed intoxication via multiple factors. | Evidence sufficient to support conviction. |
Key Cases Cited
- Armfield v. State, 918 N.E.2d 316 (Ind.2009) (reasonable suspicion standard for investigatory stops)
- Powell v. State, 912 N.E.2d 853 (Ind.Ct.App.2009) (consensual encounters vs seizures; three levels of investigation)
- Augustine, 851 N.E.2d 1022 (Ind.Ct.App.2006) (consensual encounter may become a Terry stop upon suspicion)
- Lefevers, 844 N.E.2d 508 (Ind.Ct.App.2006) (not seized when officer talks without lights activated)
- United States v. Mendenhall, 446 U.S. 544 (U.S. 1980) (test for show of authority and seizure)
- California v. Hodari D., 499 U.S. 621 (U.S. 1991) (show of authority evaluated objectively)
- Alabama v. White, 496 U.S. 325 (U.S. 1990) (anonymous tips and reasonable suspicion)
- Fought v. State, 898 N.E.2d 447 (Ind.Ct.App.2008) (impairment evaluated by totality of factors)