HUFFMAN v. STATE (2024)

MEMORANDUM DECISION

Case Summary

[1] Mitchel Huffman appeals his conviction for Class A misdemeanor domestic battery,¹ raising one issue for our review: does sufficient evidence support his conviction? We affirm.

Facts and Procedural History

[2] On February 5, 2023, Huffman met his girlfriend, Theresa Bradley, and Bradley's roommate, Kloe Grandstaff, at a bar to celebrate Bradley's birthday. At one point, Grandstaff and Huffman got into an argument that ended with Grandstaff leaving the bar. Huffman and Bradley left shortly after. When Huffman tried to start his truck, he broke off his key in the ignition. Bradley then offered him a ride, and Huffman had his truck towed to Bradley's house.

[3] The next day, Huffman was outside Bradley's home working on his truck. Bradley decided to leave and began slowly backing her truck down her hilly driveway. Huffman noticed her leaving, ran to Bradley's truck, opened the passenger door, put the truck in park, and began yelling at Bradley. As they were arguing, Bradley said she wanted to break up and Huffman told her no. When Bradley tried to exit her truck, Huffman grabbed her by her arms and held her against her truck for “at least ten minutes.” Tr. Vol. 2 at 7. Huffman would not let Bradley leave. Grandstaff, who had been watching Bradley leave, went over to Bradley's truck and tried to insert herself between Bradley and Huffman. Grandstaff began yelling at Huffman. Eventually, Bradley persuaded Huffman to let her go by saying she was not breaking up with him and would return in an hour. Huffman responded by grabbing the back of her head and trying to give her a “hickey” on her neck, saying, “I hope he sees that.” Id. at 6. Bradley and Grandstaff got into Bradley's truck and left. Bradley estimated the entire incident lasted just under two hours.

[4] The State charged Huffman with Class A misdemeanor domestic battery. Following a bench trial, Huffman was found guilty as charged.

Sufficient Evidence Supports Huffman's Conviction

[5] Huffman claims the State failed to present sufficient evidence to support his conviction. A sufficiency-of-the-evidence claim warrants a “deferential standard of appellate review, in which we ‘neither reweigh the evidence nor judge witness credibility[.]’ ” Owen v. State, 210 N.E.3d 256, 264 (Ind. 2023) (quoting Brantley v. State, 91 N.E.3d 566, 570 (Ind. 2018), cert. denied). Instead, we respect the fact-finder's exclusive province to weigh conflicting evidence, Phipps v. State, 90 N.E.3d 1190, 1195 (Ind. 2018), and consider only the probative evidence and reasonable inferences that support the judgment of the trier of fact, Hall v. State, 177 N.E.3d 1183, 1191 (Ind. 2021). We will affirm the conviction unless no reasonable factfinder could find the elements of the crime proven beyond a reasonable doubt. Teising v. State, 226 N.E.3d 780, 783 (Ind. 2024). It is “not necessary that the evidence ‘overcome every reasonable hypothesis of innocence.’ ” Sallee v. State, 51 N.E.3d 130, 133 (Ind. 2016) (quoting Moore v. State, 652 N.E.2d 53, 55 (Ind. 1995)).

[6] To prove Huffman committed Class A misdemeanor domestic battery, the State was required to show beyond a reasonable doubt that Huffman knowingly or intentionally touched Bradley—a family or household member—in a rude, insolent, or angry manner. See I.C. § 35-42-2-1.3(a)(1). Although “rude,” “insolent,” or “angry” are not separately defined in Indiana's domestic battery statute, “these disjunctive terms of art have plain and ordinary meanings readily susceptible of application by a factfinder.” In re Hill, 144 N.E.3d 184, 188 (Ind. 2020) (providing dictionary definitions for each term).

[7] On appeal, Huffman argues the evidence was insufficient to show he touched Bradley in a rude, insolent, or angry manner, claiming the State's evidence on this element was “exceedingly thin.” Appellant's Br. at 8. We disagree. During an argument, Huffman grabbed Bradley by her arms, held her against her truck for about ten minutes, and prevented her from leaving. Moreover, Huffman grasped Bradley's head and attempted to mark her neck with his mouth. Huffman also claims portions of Bradley's testimony were “wholly unbelievable” and “inconsistent” with Grandstaff's testimony. Id. at 9. But this is merely a request to reweigh the evidence and judge witness credibility; tasks we cannot undertake. See Owen, 210 N.E.3d at 264. In sum, the State presented sufficient evidence from which a reasonable finder of fact could find beyond a reasonable doubt Huffman knowingly or intentionally touched Bradley in a rude, insolent, or angry manner.

Conclusion

[8] Sufficient evidence supports Huffman's conviction.

[9] Affirmed.

FOOTNOTES

1.   Ind. Code § 35-42-2-1.3(a)(1) (2021).

Kenworthy, Judge.

May, J., and Vaidik, J., concur.