FAIRCHILD v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] On February 9, 2024, Rachel Lynn Fairchild twice bit Anthony Riddle on the arm, causing Riddle pain. Riddle testified that Fairchild had been angry but coherent during the altercation. The State charged Fairchild with Level 6 felony battery causing moderate bodily injury and, following a bench trial, the trial court found Fairchild guilty and sentenced her to a twenty-seven-month term, with nine months executed and eighteen months suspended to probation. Fairchild contends that the evidence is insufficient to sustain her conviction. Concluding otherwise, we affirm.

Facts and Procedural History

[2] On February 9, 2024, Fairchild was a patient in an adult acute unit at a hospital. Riddle, a security guard at the hospital, encountered Fairchild, who “was agitated and naked and refusing to put on clothes in public.” Tr. Vol. II p. 7. Fairchild “had left [her] room naked going to the dayroom and then went back to [her] room with some food.” Tr. Vol. II p. 7. Fairchild had urinated in her room and appeared “[a]ngry and agitated.” Tr. Vol. II p. 7.

[3] Riddle and South Bend Memorial Hospital Police Officer Kevin Slaughter responded to a request for assistance with Fairchild. Riddle attempted to “verbally communicate with [Fairchild] to de-escalate her.” Tr. Vol. II p. 15. Fairchild “was able to communicate that she was wanting a shower at one point, and she was able to converse back and forth.” Tr. Vol. II p. 8. “[T]here was a lot of back-and-forth conversation about what [Fairchild] wanted, plus the [hospital] staff was trying to keep her safe.” Tr. Vol. II p. 20. Fairchild “seem[ed] to understand what [hospital] staff were talking to her about” and “was negotiating with them to get what she wanted[,]” which was to walk to the shower naked. Tr. Vol. II p. 20. While Fairchild was “angry and defiant” and used “[a] lot of profanity[,]” Tr. Vol. II p. 20, she was, “at the very least[,]” coherent and “seem[ed] to understand what was happening.” Tr. Vol. II p. 8.

[4] Riddle attempted to restrain Fairchild, for her safety and that of the staff, “after she had punched herself in the face twice.” Tr. Vol. II p. 8. As Riddle worked to restrain her, Fairchild bit Riddle on the top of his left forearm. The bite broke Riddle's skin, drawing blood and causing bruising. The bite also caused Riddle to suffer significant pain, which Riddle ranked as a “7 out of 10.” Tr. Vol. II p. 11. Fairchild subsequently grabbed Riddle's wrist and bit him a second time causing a light bruise and pain, which Riddle ranked at the level of a “3 out of 10.” Tr. Vol. II p. 11. Fairchild eventually calmed down and, after agreeing to cover herself with a sheet, was taken to the shower. Riddle received medical treatment for his injuries and then returned to work.

[5] On February 11, 2025, the State charged Fairchild with Level 6 felony battery resulting in moderate bodily injury and Class A misdemeanor battery resulting in bodily injury. A bench trial commenced on July 10, 2025. On July 15, 2025, the trial court found Fairchild guilty of Level 6 felony battery resulting in moderate bodily injury. In support, the trial court made the following findings:

5) [Fairchild] was credibly identified as the person ․ involved in the incident at issue.

6) [Riddle] testified that [Fairchild] was communicative and apparently aware of her surroundings and the current situation.

7) According to testimony of Captain Slaughter, [Fairchild] engaged in negotiation for her wishes.

8) [Riddle] testified that [Fairchild] was agitated. The Court finds that this means she was angry.

9) The photographic exhibits ․ corroborate testimony from [Riddle] and show [Fairchild] biting [Riddle].

10) [Riddle] testified that there was another, earlier bite from [Fairchild] as well. This testimony was uncontradicted.

11) State's exhibit 2 shows an injury to [Riddle's]’s arm which he attributed to [Fairchild] biting him.

12) [Riddle] testified that one of the bites from [Fairchild] was a 3/10 for pain, while the other bite was a 7/10 for pain.

Appellant's App. Vol. II p. 36. The trial court further found that “[a]s to Count II, the Court finds that double jeopardy prevents a verdict or judgment upon Count II, therefore none will issue.” Appellant's App. Vol. II p. 36. The trial court sentenced Fairchild to a twenty-seven-month term, with nine months executed and eighteen months suspended to probation.

Discussion and Decision

[6] When reviewing the sufficiency of the evidence to support a conviction, appellate courts must consider only the probative evidence and reasonable inferences supporting the verdict. It is the fact-finder's role, not that of appellate courts, to assess witness credibility and weigh the evidence to determine whether it is sufficient to support a conviction. To preserve this structure, when appellate courts are confronted with conflicting evidence, they must consider it most favorably to the trial court's ruling. Appellate courts affirm the conviction unless no reasonable fact-finder could find the elements of the crime proven beyond a reasonable doubt. It is therefore not necessary that the evidence overcome every reasonable hypothesis of innocence. The evidence is sufficient if an inference may reasonably be drawn from it to support the verdict.

Drane v. State, 867 N.E.2d 144, 146–47 (Ind. 2007) (internal brackets, citations, emphasis, and quotations omitted). Stated differently, in reviewing 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).

[7] Fairchild was convicted of Level 6 felony battery resulting in moderate bodily injury. “[A] person who knowingly or intentionally: (1) touches another person in a rude, insolent, or angry manner; or (2) in a rude, insolent, or angry manner places any bodily fluid or waste on another person; commits battery[.]” Indiana Code § 35-42-2-1(c). The offense is a Level 6 felony if “[t]he offense results in moderate bodily injury to any other person.” Indiana Code § 35-42-2-1(e)(1). “ ‘Moderate bodily injury’ means any impairment of physical condition that includes substantial pain.” Ind. Code § 35-31.5-2-204.5.

[8] “A person engages in conduct ‘intentionally’ if, when [s]he engages in the conduct, it is [her] conscious objective to do so.” Ind. Code § 35-41-2-2(a). “A person engages in conduct ‘knowingly’ if, when [s]he engages in the conduct, [s]he is aware of a high probability that [s]he is doing so.” Ind. Code § 35-41-2-2(b). Moreover, “[a] person commits an offense only if [s]he voluntarily engages in conduct in violation of the statute defining the offense.” Ind. Code § 35-41-2-1(a).

[9] Indiana Code section 35-41-2-1(a) “codified the axiom that voluntariness is a general element of criminal behavior and reflected the premise that criminal responsibility postulates a free agent confronted with a choice between doing right and doing wrong and choosing freely to do wrong.” Baker v. State, 208 N.E.3d 626, 638 (Ind. Ct. App. 2023) (quotation omitted), trans. denied. “Once evidence in the record raises the issue of voluntariness, the State must prove beyond a reasonable doubt that the defendant acted voluntarily. If the State fails to prove that a defendant's conduct was voluntary, it has not proved every element of the offense.” Id. (quotation omitted).

[10] Fairchild does not challenge the sufficiency of the State's evidence to prove that she bit Riddle but rather that she had acted voluntarily and with the requisite mens rea. Specifically, Fairchild argues that

[t]he evidence shows that she was agitated, had urinated on the floor, was refusing to dress and was beating herself about the head.․ All facts indicate that she was in the midst of a severe mental health crisis and was as much a danger to herself as to others in her then mental state. No deductive logical inference can be drawn (much less drawn beyond a reasonable doubt) that Fairchild was aware of her surroundings in any significant sense or acting voluntarily and knowingly during the events critical to her conviction.

Appellant's Br. pp. 15–16.

[11] Indiana Evidence Rule 704(b) provides that “[w]itnesses may not testify to opinions concerning intent, guilt, or innocence in a criminal case[.]”

Generally, the opinion rule excludes an eyewitness's conclusion as to the state of mind of another person. This is the province of the jury, which is equally able to infer a person's state of mind or emotions from testimony limited to particular facts and circumstances observed by the eyewitness. Although there is authority for a different view, the jury determines the psychological facts; the witness is limited in his testimony to the indicia he observed.

Strickland v. State, 265 Ind. 664, 669, 359 N.E.2d 244, 248 (1977) (citations omitted). However, with regard to the similar mental-state question of whether a defendant was sane at the time he committed a criminal act, the Indiana Supreme Court has held that lay opinion testimony, “when considered in light of the other evidence, permits a reasonable inference of sanity to be drawn.” Galloway v. State, 938 N.E.2d 699, 712 (Ind. 2010). The Supreme Court went on to state that

[c]redible and informed lay opinion testimony as to the defendant's mental state at the time of the crime may be sufficiently probative to support a trier of fact's determination of sanity[.․] Lay witnesses who are familiar with and observe the defendant at or around the time of the crime reasonably may be able to give a more accurate account of the defendant's mental state at the time of the crime than experts who examine the defendant months later.

Id. (citations omitted). We conclude that the same is true for informed lay testimony regarding a defendant's actions and apparent mental state at the time of crime in that it may likewise be considered probative evidence that would support a fact-finder's determination regarding whether a defendant acted voluntarily.

[12] In this case, both Riddle and Officer Slaughter testified that Fairchild had been able to communicate and to converse back and forth during the altercation. Officer Slaughter testified that “there was a lot of back-and-forth conversation about what [Fairchild] wanted, plus the [hospital] staff was trying to keep her safe.” Tr. Vol. II p. 20. Fairchild “seem[ed] to understand what [hospital] staff were talking to her about” and “was negotiating with them to get what she wanted.” Tr. Vol. II p. 20. While Fairchild was “angry and defiant” and used “[a] lot of profanity[,]” Tr. Vol. II p. 20, Riddle testified that she was, “at the very least[,]” coherent and “seem[ed] to understand what was happening.” Tr. Vol. II p. 8.

[13] Neither Riddle nor Officer Slaughter gave an impermissible opinion as to whether Fairchild acted voluntarily, knowingly, or intentionally. The trial court, acting at the trier-of-fact, however, was free to consider their testimony regarding their observations of Fairchild in determining that Fairchild had acted voluntarily and with the requisite mens rea. This is precisely what the trial court did, finding that “the State has met its burden of proof.” Appellant's App. Vol. II p. 36. Fairchild's argument on appeal amounts to nothing more than a request to reweigh the evidence, which we will not do. See Griffith, 59 N.E.3d at 958.

[14] The judgment of the trial court is affirmed.

Bradford, Judge.

Pyle, J., and Kenworthy, J., concur.