TAYLOR v. STATE (2025)

MEMORANDUM DECISION

Case Summary

[1] Following a jury trial, Derrick Taylor was convicted of domestic battery, a Class A misdemeanor, and the trial court sentenced Taylor to time served. Taylor appeals and claims: (1) the State presented insufficient evidence to support his conviction; and (2) the trial court erred by not releasing him from home detention immediately after the jury trial. We conclude that the evidence is sufficient to support Taylor's conviction and that, although the trial should have released Taylor from home detention immediately, we can afford Taylor no effective relief. Accordingly, we affirm Taylor's conviction.

Issues

[2] Taylor presents two issues, which we reorder and restate as:

I.  Whether the State presented sufficient evidence to support Taylor's conviction for domestic battery.

II. Whether trial court should have released Taylor from home detention immediately after trial.

Facts

[3] At the time relevant to this appeal, the victim in this case, S.T., was Taylor's ex-girlfriend. S.T. suffered from alopecia, which causes hair loss, and wore a wig. On October 6, 2023, S.T. walked to her car from her place of employment in Indianapolis and saw Taylor approaching her. S.T. got inside her car, but when she tried to close the door, Taylor grabbed the door and stopped her from closing it. Taylor grabbed S.T.’s wig and pulled it off her head. As the wig was glued to S.T.’s head, this caused S.T. pain. Taylor took the wig and walked to his own car. S.T. followed Taylor to his car to retrieve her wig. S.T. got into Taylor's car and asked for the wig, but Taylor held it out of her reach. Taylor then gave S.T. the wig and drove away with S.T. still in the car.

[4] As he drove, Taylor cursed and screamed at S.T. and accused her of being with another man. S.T. remained silent because she was scared. After several minutes of driving, Taylor eventually slowed his car, and S.T. jumped out. Taylor got out of his car and followed her. S.T. ran into traffic and knocked on the window of a passing car. The driver of the car, J.E., was scared but rolled down her window to see what S.T. wanted. S.T. stated that Taylor was following her and that she needed to escape. J.E. unlocked her car doors and told S.T. to get in. Before S.T. could get in the car, however, Taylor caught up to her, grabbed her feet, and tried to pull her out of the car. S.T. kicked her legs to escape from Taylor's grasp, but Taylor grabbed her arms and was again able to pull S.T.’s wig off. J.E. got out of her car and tried to help S.T., but by the time she did, S.T. had managed to kick Taylor away and close the door. J.E. got back into her car and drove S.T. to safety as S.T. called the police.

[5] Officers from the Indianapolis Metropolitan Police Department responded to the call. S.T. was still shaken from the incident, and upon examination of S.T., the officers observed swelling and bruising on S.T.’s right wrist and scrapes on S.T.’s left knee. The officers also took photos of S.T.’s injuries and obtained surveillance video from S.T.’s employer, which depicted Taylor approach S.T.’s car and S.T. later walk to Taylor's car.

[6] On October 19, 2023, the State charged Taylor with Count I, kidnapping, a Level 3 felony; Count II, intimidation, a Level 5 felony; Count III, domestic battery, a Class A misdemeanor; Count IV, battery resulting in bodily injury, a Class A misdemeanor; and Count V, domestic battery by bodily waste, a Class A misdemeanor. The trial court found probable cause to issue a warrant for Taylor's arrest and set bond at $30,000. Taylor was arrested on the warrant in November 2023. Taylor subsequently posted bond and was released on home detention with GPS monitoring. Taylor remained on home detention until the conclusion of the jury trial. On August 27, 2024, the day before the jury trial, the State dismissed Count IV. The jury found Taylor guilty of Count III, domestic battery, but not guilty of the remaining charges. At 8:10 p.m., after an almost twelve-hour jury trial, Taylor's counsel informed the trial court, “[Taylor] has been on home [detention] since October,” and asked if the court would “consider nullifying that at this point?” Tr. Vol. IV p. 37. The trial court responded, “Nah. I'll deal with it Wednesday.”¹ Id.

[7] At the August 30, 2024 sentencing hearing, the trial court gave Taylor credit for eight days he spent in jail and 286 days he spent on home detention. With good time credit, this was more than the maximum sentence for a Class A misdemeanor. Accordingly, the trial court sentenced Taylor to time served and released him. Taylor now appeals.

Discussion and Decision

I. Sufficient evidence supports Taylor's conviction.

[8] Taylor claims that the State presented insufficient evidence to support his conviction for domestivc battery, a Class A misdemeanor. “Claims of insufficient evidence ‘warrant a deferential standard, in which we neither reweigh the evidence nor judge witness credibility.’ ” Stubbers v. State, 190 N.E.3d 424, 429 (Ind. Ct. App. 2022) (quoting Powell v. State, 151 N.E.3d 256, 262 (Ind. 2020)), trans. denied. On appeal, “[w]e consider only the evidence supporting the judgment and any reasonable inferences drawn from that evidence.” Id. (citing Powell, 151 N.E.3d at 262). “ ‘We will affirm a conviction if there is substantial evidence of probative value that would lead a reasonable trier of fact to conclude that the defendant was guilty beyond a reasonable doubt,’ ” and we will affirm a conviction “ ‘unless no reasonable fact-finder could find the elements of the crime proven beyond a reasonable doubt.’ ” Id. (quoting Powell, 151 N.E.3d at 262).

[9] To convict Taylor of domestic battery, a Class A misdemeanor, the State was required to prove that Taylor knowingly or intentionally touched S.T., who was a family or household member, in a rude insolent or angry manner. Ind. Code § 35-42-2-1.3(a)(1). “An individual is a ‘family or household member’ of another person if the individual: ․ (2) is dating or has dated the other person; or (3) is or was engaged in a sexual relationship with the other person.” Ind. Code § 35-31.5-2-128(a).

[10] Here, the State presented evidence that Taylor and S.T. had dated, and Taylor does not deny that there was evidence showing that S.T. was a “family or household member” as that term is defined by statute. Contrary to Taylor's claim, there is also evidence that Taylor knowingly or intentionally touched S.T. in a rude, insolent, or angry manner. S.T. testified that Taylor pulled her wig off and grabbed her by her arms and legs. Taylor was angry with S.T., accused her of having an intimate relationship with another man, yelled and cursed at her, and called her derogatory names. S.T. had a bruise on her wrist and scrapes on her knee. From this evidence, the jury could reasonably conclude that Taylor touched S.T. in a rude, insolent, or angry manner. Thus, sufficient evidence supports Taylor's conviction for domestic battery. See Perry v. State, 78 N.E.3d 1, 9-10 (Ind. Ct. App. 2017) (holding that sufficient evidence supported domestic battery conviction where victim's eyewitness statements and the physical evidence indicated that defendant hit victim in the face).

II. Taylor should have been released from home detention immediately after trial, but the issue is moot.

[11] Taylor also argues that the trial court erred by not releasing him from home detention immediately after the jury's verdict. The trial court determined that Taylor spent 295 days in jail or on home detention. The trial court also gave Taylor 295 days of good-time credit, for a total of 590 days. This is 225 days more than the maximum sentence of 365 days for a Class A misdemeanor.² See Ind. Code § 35-50-3-2. Taylor is, therefore, correct that, by waiting two days until the sentencing hearing to order Taylor to be released from home detention, the trial court kept Taylor on home detention longer than the maximum allowable sentence.

[12] Taylor admits, however, that we cannot afford him any effective relief. We cannot order the trial court to “give back” Taylor the two days he was on home detention following the verdict. Thus, this issue is moot. See Breedlove v. State, 20 N.E.3d 172, 174 (Ind. Ct. App. 2014) (holding that court could afford no relief, and issue was moot, where defendant, who claimed that his community corrections placement had been improperly revoked, had already served his sentence in the Department of Correction).

[13] Taylor, however, argues that we should address the merits of his claim under the “public interest” exception to the mootness rule. As we explained in Breedlove:

Indiana courts have long recognized that a case may be decided on its merits under an exception to the general [mootness] rule when the case involves questions of great public interest. Cases in this category typically raise important policy concerns and present issues that are likely to recur.

20 N.E.3d at 173 (citations and internal quotations omitted).

[14] Here, we exercise our discretion to address Taylor's argument under the public interest exception to the mootness doctrine. It is clear that the maximum sentence for a Class A misdemeanor is one year. Ind. Code § 35-50-3-2. It is equally clear that a person convicted of a Class A misdemeanor earns one day of accrued time credit for each day he or she is on pretrial home detention. See Ind. Code § 35-50-6-4(a) (providing that a person who is not a credit restricted felon and is imprisoned awaiting trial for a Level 6 felony or misdemeanor is initially assigned to Class A for credit time purposes); Ind. Code § 35-50-6-3.1(b)(3) (providing that a person assigned to Class A earns one day of good-time credit for each day the person is on pretrial home detention).³ And it is axiomatic that a prisoner cannot be lawfully held beyond the maximum sentence. Tahash v. Clements, 125 N.E.2d 439, 441 (Ind. 1955); see also Ind. Code § 35-50-6-2 (“A person imprisoned for a misdemeanor shall be discharged when he completes his fixed term of imprisonment, less the credit time he has earned with respect to that term.”).

[15] Although we cannot give Taylor back the two extra days he was on home detention, we strongly advise trial courts and counsel to be aware of such credit time issues and strive to ensure that defendants are not held in jail or on home detention longer than their maximum sentences.

Conclusion

[16] The State presented sufficient evidence to support Taylor's conviction for domestic battery, a Class A misdemeanor. Although the issue is moot, Taylor is correct that the trial court should have released him from home detention immediately after the jury's verdict. Accordingly, we affirm.

[17] Affirmed.

FOOTNOTES

1.   The sentencing hearing was initially scheduled to be held on Wednesday, September 4, 2024. The day after trial, however, the trial court reset the sentencing hearing for the next day, August 30, 2024.

2.   Taylor, however, did not mention this to the trial court when he asked to be released from home detention at the end of the jury trial.

3.   Taylor was charged with a Level 4 felony, a Level 5 felony, and a Class A misdemeanor. A person who is not a credit restricted felon and imprisoned or awaiting trial for anything other than a Level 6 felony or misdemeanor is initially assigned to Class B for credit time purposes. I.C. § 35-50-6-4(b). A person assigned to Class B earns one day of good-time credit for every three days the person is on pretrial home detention. I.C. § 35-50-6-3.1(c)(3). The trial court assumed Taylor was in Class A for credit time purposes, and the State does not argue otherwise. Even if Taylor was in Class B, however, he would have had ninety-eight days of good time credit, for a total of 393 days, twenty-eight days longer than the maximum sentence for a Class A misdemeanor. Thus, regardless of whether Taylor was in Class A or Class B for credit time purposes, he had been on home detention longer than the maximum sentence for a Class A misdemeanor and was entitled to immediate release.

Tavitas, Judge.

Altice, C.J., and Brown, J., concur.