Joseph A. Uhlir, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] Joseph Uhlir appeals his conviction for driving while suspended, a Class A misdemeanor, challenging the sufficiency of the evidence. Uhlir maintains that his conviction must be reversed because the State failed to establish that it was his driving record that was admitted into evidence at trial.  ¹

[2] We affirm.

Facts and Procedural History

[3] On January 13, 2025, Indiana State Police Trooper Joseph Malone (Trooper Malone), while on routine patrol in Indianapolis, observed Uhlir driving a truck without wearing a seatbelt. Trooper Malone also learned that the license plate did not match the truck that Uhlir was driving.

[4] Trooper Malone stopped the vehicle, and at some point, Uhlir told Trooper Malone that he did not have a driver's license because it was suspended. Uhlir also admitted that he had no registration for the vehicle.

[5] A K9 unit arrived at the scene and the dog alerted to the vehicle. Another State Trooper searched the truck and found a “broken smoking device ․ with white powder residue” between the driver seat and the center cushion. Transcript Vol. II at 11, 20. Uhlir told one of the officers that “he picked up the vehicle the night before” and “didn't know what was inside. ” Id. at 11. The officers did not confiscate the device because it was broken.

[6] On February 5, 2025, the State charged Uhlir with driving while suspended, a Class A misdemeanor, possession of paraphernalia, a Class C misdemeanor, operating a vehicle without financial responsibility, a Class A infraction, operating a vehicle with a false plate, a Class C infraction, and failure to use a seat belt, a Class D infraction.

[7] During a bench trial on November 13, 2025, Uhlir objected to the admissibility of an Indiana Bureau of Motor Vehicles driving record because “there was no testimony to the date of the birth of Uhlir to connect him to that record.” Id. at 33. The certified copy of the driving record set forth Uhlir's name, date of birth, and driver's license number. The trial court admitted the driving record over the objection and found Uhlir guilty on all counts except for possession of paraphernalia. The trial court sentenced Uhlir to 180 days of probation and thirty hours of community service.

[8] Uhlir now appeals, challenging only the driving while suspended conviction.

Discussion and Decision

[9] When addressing challenges to the sufficiency of the evidence, “we consider only the evidence and reasonable inferences most favorable to the convictions, neither reweighing evidence nor reassessing witness credibility” and “affirm the judgment unless no reasonable factfinder could find the defendant guilty.” Griffith v. State, 59 N.E.3d 947, 958 (Ind. 2016).

[10] Uhlir was convicted of violating Ind. Code § 9-24-19-2, which provides

An individual who:

(1) knows that the individual's driving privileges, driver's license, or permit is suspended or revoked; and

(2) operates a motor vehicle upon a highway․

commits a Class A misdemeanor.

(Emphasis added).

[11] Even though Uhlir's name, date of birth, and driver's license number were listed on the driving record, he contends that the State presented insufficient evidence because there was no testimony at trial tying him to the driving record. The driving record aside, Trooper Malone testified that Uhlir was operating a motor vehicle on Raymond Street in Indianapolis when he stopped him for committing an infraction. Trooper Malone further testified that Uhlir admitted that his driver's license was suspended at that time. His testimony, along with Uhlir's admission of his suspension, was sufficient to prove that Uhlir committed the charged offense. Cf. State v. Jackson, 889 N.E.2d 819, 823 (Ind. 2002) (determining that “the defendant's statement to police that his license was suspended provided direct proof of the knowledge element for the offense of driving while suspended․”).

[12] Judgment affirmed.

FOOTNOTES

1.   [1] Uhlir also contends for the first time on appeal that the driving record was prejudicial because it allegedly included unrelated suspensions. That issue is waived because Uhlir failed to present that claim at trial. See JK Harris & Co., LLC v. Sandlin, 942 N.E.2d 875, 882 (Ind. Ct. App. 2011), trans. denied.

Altice, Judge.

Brown, J. and DeBoer, J., concur.