Jeffrey T. Rawls, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] Jeffrey T. Rawls appeals his conviction for Level 5 felony domestic battery resulting in bodily injury to a person less than 14 years old, arguing that the State failed to rebut his defense of parental privilege. We affirm.

Facts and Procedural History

[2] During the 2023-24 school year, Rawls's son, J.R., was in second grade and lived with Rawls in Washington, Indiana. J.R.’s mother lived in Kentucky. J.R. was a “smart kid” and did well in school “[w]hen he applied himself.” Tr. Vol. 2 p. 182. He also had behavioral problems.

[3] On January 9, 2024, when J.R. was seven years old, his teacher sent home report cards and “i-Ready assessment scores.”¹ Id. at 177. While J.R.’s grades were “average,” his i-Ready assessment score placed him at the kindergarten level. Id. at 182.

[4] When J.R. arrived at school the next day, January 10, J.R.’s teacher noticed that he was walking with a limp, which he normally didn't do. The teacher asked J.R. what happened and sent him to the school social worker. The teacher, as a mandated reporter of suspected child abuse and neglect, called the Indiana Department of Child Services (DCS) hotline.

[5] That same day, DCS assessment worker Pamela Padgett went to J.R.’s school and interviewed him. J.R. told her that his leg hurt, and Padgett observed “several linear marks” on his “left upper thigh.” Id. at 202; see Exs. 1-3 (photos). Padgett contacted the police, and she and Washington City Police Department Detective Stacy Reese went to Rawls's house to speak with him. Detective Reese wore a body camera, which captured the interaction. See Ex. 4. Rawls, who was “forthcoming,” said he “whipped” J.R. with a “belt” on his “butt and leg” “two times” because of his i-Ready assessment score. Tr. Vol. 2 p. 204. Detective Reese asked Rawls if he could find the belt that he used, but Rawls couldn't find it. Detective Reese asked Rawls if there was “any other reason” besides the i-Ready assessment score that he spanked J.R., and Rawls said, “That's it.” Ex. 4 at 9:11. Upon further questioning, Rawls admitted that he was a “strong man” and might've “over swapped” J.R. Id. at 15:54. Rawls added that he often received phone calls from J.R.’s principal about his “behavior,” including “cursing,” “touching girls’ booty,” and “biting kids.” Id. at 18:10-18:16. Rawls said he had taken away J.R.’s PlayStation in the past but had become “fed up” the night before. Id. at 18:20.

[6] Padgett returned to the school, which was getting ready to be dismissed for the day, and picked up J.R. and took him to the hospital for an exam. Detective Reese met them at the hospital, and she observed “three to four” “marks on [J.R.’s] legs,” which appeared to be from a belt or cord. Tr. Vol. 2 p. 231.

[7] Nurse Practitioner Tiffany Turner examined J.R., and he told her that his “thighs” hurt from a “spanking” the night before. Tr. Vol. 3 p. 4. According to J.R., Rawls “whipped” him with a “phone cord” because he couldn't find his “belt.” Id. at 9. NP Turner documented that J.R. had “[b]ilateral thigh contusions”—that is, bruising on his right and left thighs—that were “linear in nature.” Id. at 7, 9. She said the bruising was consistent with a “phone cord,” not a “belt.” Id. at 11-12. She also documented that J.R. had a circular bruise on his right thigh. The bruises “hurt to the touch,” but J.R. was not limping. Id. at 9. J.R. was discharged with instructions to apply ice for the next two days. Padgett decided to remove J.R. from Rawls and place him in a licensed foster home (he was later placed with his mother in Kentucky).

[8] The next day, January 11, Padgett met with Rawls, and he claimed that “he felt like he had the right as a father to discipline his child in the manner that he did.” Tr. Vol. 2 p. 211. When shown the photos, he “scoffed it off and just stated that it ․ was insignificant. That it was nothing.” Id. at 212.

[9] The State charged Rawls with Level 5 felony domestic battery resulting in bodily injury to a person less than 14 years old. A jury trial was held in August 2024. Rawls asserted the parental-privilege defense. J.R., who lived in Kentucky with his mother, did not appear. Rawls appeared for the first two days but not the third, and an arrest warrant was issued for him. Padgett, Detective Reese, and NP Turner testified as detailed above, and the footage from Detective Reese's body camera was played for the jury. In addition, J.R.’s principal testified as a defense witness. He said that J.R. had been suspended twice that school year and that he had talked to Rawls on the phone five times about J.R.’s behavioral issues, with the last time being on December 18, 2023. Tr. Vol. 3 pp. 38, 46. The principal said that shortly after the school year started in August, he recommended MTSS (multi-tiered system of supports) for J.R. due to his behavioral issues, but Rawls never filled out the permission slip. According to the principal, most families take advantage of MTSS.

[10] During closing arguments, defense counsel argued that J.R. was “a terror in school” and that this case was about “reasonable parental discipline over a child who misbehaves in school and doesn't try ․ to do his best on a test.” Id. at 67-68. Defense counsel claimed that J.R.’s i-Ready assessment score was “the straw that broke the camel's back.” Id. at 68. Defense counsel told the jury that it should take Rawls at his word that he used a belt, which was “a time-honored tradition” of discipline in the United States practiced by “many, many parents.” Id. at 69. In response, the State argued that Rawls knew his actions weren't reasonable because he claimed to have used a belt when he really used a cord. The jury, which was instructed on the parental-privilege defense, see Appellant's App. Vol. 2 p. 204, found Rawls guilty.

[11] Almost a year later, Rawls was arrested on the warrant in Florida and returned to Indiana for sentencing. The trial court sentenced him to four years, with 30 months in the Department of Correction and the last 18 months on work release.

[12] Rawls now appeals.

Discussion and Decision

[13] Rawls contends that the State failed to rebut his claim of parental privilege, which is a complete defense to the domestic-battery charge. We apply the same standard of review as for any sufficiency-of-the-evidence claim. Willis v. State, 888 N.E.2d 177, 182-83 (Ind. 2008). We neither reweigh the evidence nor judge the credibility of the witnesses, and we only consider the evidence most favorable to the conviction. See id. at 183.

[14] “[T]o sustain a conviction for battery where a claim of parental privilege has been asserted, the State must prove that either: (1) the force the parent used was unreasonable or (2) the parent's belief that such force was necessary to control [their] child and prevent misconduct was unreasonable.” Id. at 182. As the jury was instructed in this case, to determine whether the force used was reasonable, the trier of fact considers the following non-exclusive factors: (1) whether the actor is a parent; (2) the age, sex, and physical and mental condition of the child; (3) the nature of the offense and the apparent motive; (4) the influence of the example upon other children of the same family or group; (5) whether the force or confinement is reasonably necessary and appropriate to compel obedience to a proper command; and (6) whether it is disproportionate to the offense, unnecessarily degrading, or likely to cause serious or permanent harm. Id.

[15] The State argues that it sufficiently rebutted Rawls's parental-privilege defense because the jury could have reasonably concluded from the evidence that the amount of force that Rawls used was unreasonable. We agree. J.R. was seven years old, and Rawls, as he himself admitted, is a “strong man.” He hit J.R. several times with a phone cord, which left linear bruises on his thighs. When Rawls told law enforcement and DCS about disciplining J.R. because of his i-Ready assessment score, he claimed to have used a belt, but he couldn't find it. He also admitted that he could have “over swapped” J.R. The bruises caused J.R. to limp the next day and were painful to the touch. And while J.R. had behavioral problems, Rawls didn't take advantage of services offered by the school. The State sufficiently rebutted Rawls's parental-privilege defense. See, e.g., Pava v. State, 142 N.E.3d 1071, 1078 (Ind. Ct. App. 2020) (“In response to P.P.’s acts of disobedience, Pava used disproportionate and degrading force against him. She struck him at least ten times with an electrical cord, leaving a multitude of painful welts all over his body. P.P. was still in pain the following day.”), trans. denied; Fernanders v. State, 112 N.E.3d 222, 226 (Ind. Ct. App. 2018) (“Fernanders spanked A.F. on her bare buttocks with a belt, multiple times, with sufficient force to leave large bruises and to cause A.F. to limp afterward․ Fernanders spanked A.F. because she volunteered an answer in class before her first-grade teacher called on her, and because A.F. had spoken out of turn on prior occasions at school.”), trans. denied. We therefore affirm Rawls's conviction for Level 5 felony domestic battery.

[16] Affirmed.

FOOTNOTES

1.   I-Ready is a computer program that provides a diagnostic math and reading assessment at the beginning, middle, and end of the school year and then provides individualized lessons based on the student's performance. Tr. Vol. 2 p. 178. It's “not a high-stakes test” and has no impact on whether a student can advance to the next grade. Id. at 179.

Vaidik, Judge.

Bailey, J., and Scheele, J., concur.