K.M., Appellant-Respondent v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] K.M. appeals her adjudication as a juvenile delinquent for having committed battery against Karen Bishop on the sole ground that there is insufficient evidence to support the adjudication. We disagree and affirm the adjudication.

Facts and Procedural History

[2] The facts most favorable to the delinquency adjudication are as follows. In May 2025, K.M. was in a residential placement at Paddock View, which also housed other juveniles. On May 7, K.M. hit N.M., who was another juvenile in the facility.

[3] On May 14, Bishop and another employee of Paddock View were watching K.M. and other juveniles for the night. Juveniles at Paddock View were not permitted to cross from the carpeted portion of rooms to the tiled portion of the facility without permission from Bishop or another employee. At some point that night, K.M crossed from the carpeted section of a room to the tiled section where Bishop was seated at her desk. Bishop informed K.M. that she needed to ask to leave the carpeted area, and K.M. said that she needed a sanitary napkin from a file cabinet. Bishop said, “[Y]ou still have to ask[,]” and K.M. went back to the carpeted area. Tr. at 21.

[4] Bishop then informed K.M. that she would have to “write [K.M.] up for” crossing to the tiled area of the room without permission. Id. K.M. said, “I don't care, I don't care” and then “blew up and rushed” to the desk where Bishop was seated. Id. Bishop stood up as K.M. approached, and K.M. hit Bishop in her face.

[5] The State filed a petition alleging K.M. was delinquent for having committed what would be two counts of Class B misdemeanor battery if committed by an adult, count one for hitting N.M. and count two for hitting Bishop. At the initial hearing on May 19, K.M. admitted to striking N.M. but denied striking Bishop. The juvenile court accepted K.M.’s admission regarding count one and placed K.M. on ninety days of detention, suspended, and probation for six months.

[6] The second count proceeded to a contested fact-finding hearing on June 30, at which both Bishop and K.M. testified. Bishop testified that K.M. had “rushed” up to Bishop's desk and “hit [Bishop] across the face,” but could not recall whether K.M. used an open hand or a fist. Id. at 21. K.M. testified that she ran up to Bishop and swung at her but “did not connect with her.” Id. at 25. A surveillance camera recorded the incident, but the system “re-tapes over itself,” so that no recording was available at the fact-finding hearing. Id. at 23.

[7] On July 18, the trial court entered a dispositional order in which it adjudicated K.M. delinquent on count two, the battery against Bishop. The trial court ordered that the original disposition previously entered for count one “applies to Count 2 as well[;]” that is, K.M.’s aggregate disposition for both counts is ninety days of detention, suspended, and probation for six months. Id. at 29. K.M. now appeals the adjudication for count two.

Discussion and Decision

[8] K.M. challenges the sufficiency of the evidence to support the delinquency adjudication for battery against Bishop. Our standard of review of the sufficiency of the evidence is well-settled. “When reviewing sufficiency claims in the special context of a juvenile adjudication, such as here, we do not reweigh the evidence or judge witness credibility but appraise only the evidence favorable to the judgment and the reasonable inferences supporting it.” A.W. v. State, 229 N.E.3d 1060, 1064 (Ind. 2024).

We will affirm if there exists substanti[al] evidence of probative value to establish every material element of the offense. Further, it is the function of the trier of fact to resolve conflicts in testimony and to determine the weight of the evidence and the credibility of the witnesses.

J.C. v. State, 131 N.E.3d 610, 612 (Ind. Ct. App. 2019) (citation omitted). We will affirm a juvenile delinquency adjudication unless no reasonable factfinder could have found the respondent guilty beyond a reasonable doubt. B.T.E. v. State, 108 N.E.3d 322, 326 (Ind. 2018).

[9] The trial court made a true finding as to count two, which alleged K.M. “did knowingly or intentionally touch PVRC staff, Karen Bishop, in a rude, angry, or insolent manner, to wit: struck [Bishop] in [sic] the left side of her face.” App. at 11. The State presented evidence from Bishop herself, who testified that K.M. “hit [Bishop] across the face.” Tr. at 21. It is well-established that “[a] conviction can be sustained on only the uncorroborated testimony of a single witness, even when that witness is the victim,” Bailey v. State, 979 N.E.2d 133, 135 (Ind. 2012), and “even where the evidence is uncorroborated,” Sallee v. State, 51 N.E.3d 130, 135 (Ind. 2016). Bishop's testimony is sufficient to support the delinquency adjudication.

[10] K.M. admits as much in her brief. However, she argues that we should abandon the long-standing standard of review in sufficiency cases that prohibits us from reweighing the evidence. This standard was established by the Indiana Supreme Court as far back as 1956, see Baker v. State, 138 N.E.2d 641, 644 (Ind. 1956), and continues to be the standard of review applied by our Supreme Court to the present time, see, e.g., A.W., 229 N.E.3d at 1064. The Indiana Court of Appeals is an intermediate appellate court, and “[i]t is not our role to reconsider or declare invalid decisions of the Indiana Supreme Court.” Fox v. Franciscan Alliance, Inc., 204 N.E.3d 320, 327 (Ind. Ct. App. 2023) (quotation marks and citation omitted), trans. denied. “In fact, we are bound by our supreme court's decisions, and its precedent is binding on us until it is changed by our supreme court or legislative enactment.” Id.

Conclusion

[11] K.M.’s adjudication as a delinquent for battery committed against Bishop is supported by substantial evidence of probative value, and we may not abandon the well-established standard of review in sufficiency cases created by the Indiana Supreme Court, as K.M. requests.

[12] Affirmed.

Bailey, Judge.

Tavitas, C.J., and Kenworthy, J., concur.