Chantel N. Hall, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] Chantel N. Hall was convicted of Class A misdemeanor theft following a bench trial. Hall raises one issue for review: Did the trial court apply the proper burden of proof in finding Hall guilty? We affirm.

Facts and Procedural History

[2] Around 4:45 p.m. on November 18, 2024, Laura Hiatt, an asset protection investigator at an Indianapolis store, observed a customer push a cart full of items past the self-check registers. The customer stopped briefly at the service desk near the front of the store, where a teenage girl joined her, before attempting to leave without paying for the items. Hiatt and Officer Jordan Curtis, an off-duty police officer working security, stopped the customer before she could leave and asked her to step into the security office. While Hiatt calculated the value of the items in the cart, Officer Curtis reviewed the customer's identification, which listed the name “Chantel Hall.” Officer Curtis verified the ID belonged to the customer “by looking at the picture.” Tr. Vol. 2 at 75. He said he had “[n]o reason at all” to believe the person pictured was not Hall. Id. at 84. Neither Hiatt nor Officer Curtis took a picture of the ID or wrote down any of the identifying information from the ID. After learning the items in the cart exceeded $600 in value, Hiatt told Officer Curtis the store wished to press charges. Officer Curtis issued a citation and told Hall she would receive a summons in the mail.

[3] The State charged Hall with Class A misdemeanor theft. At the bench trial, the State admitted into evidence store surveillance footage of Hall pushing her cart past the self-check scanners, of Hiatt confronting Hall as she walked out of the store, and of Hall in the security office. Both Hiatt and Officer Curtis identified Hall at trial as the person they encountered at the store the day of the theft.

[4] Hall testified she was not at the store on November 18. She said she had tripped on a curb and “messed up [her] ankle” the day before. Id. at 88. She went to urgent care and had an x-ray done. Because Hall was scheduled to work the next day, the doctor wrote her an excuse from work and advised her to rest, ice, and elevate her ankle. Hall's ankle was still painful and swollen on November 18. She testified she stayed home with her boyfriend and rested, aside from putting her kids on the school bus and then picking them up from daycare at 5:30 p.m. Hall said she was not the person in the surveillance videos, pointing out several inconsistencies—noting, for instance, that the woman in the video was not limping and was not wearing glasses, whereas Hall was still limping on November 18 and needed glasses to see. She also said she had lost several IDs in recent years. Hall's boyfriend also testified and said he “[c]hilled in the house with her” all day on November 18 until she left to pick up her children around 5:00 p.m. Id. at 112. After closing arguments, the trial court took the ruling under advisement.

[5] At a hearing two weeks later, the trial court found Hall guilty of Class A misdemeanor theft. In announcing its verdict, the trial court noted the State had presented testimony from two eyewitnesses, both of whom identified “the Defendant that is here today as the person they had contact ․ with on the day at issue[.]” Id. at 135. The court also noted Hall testified and stated “she was not there. It was not her in [the] video[;] ․ she was at a different location picking up her kids[.]” Id. at 136. And the court said the State's video evidence was “from a distance, so it ․ does not offer a precise observation to the person's face[.]” Id. The court then explained:

One (1) of the instructions that I read to the jury when they get a case is they are to use common sense in evaluating the facts as well as they are free to take into account any biases that a witness may have when they testify. It is clear to me that here we have a case of two (2) compete-competing sets of facts, uh, put forth by each side. So, as, as the trier of fact I have to decide which set of facts is more compelling and reasonable to accept. Based on that, I do find that the State has met its burden in the case. I am not willing to discount the fact that two (2) individuals both performing their jobs with no other motive other than to do their job, uh, came into Court and testified that this Defendant was the one (1) that they saw at the store on the day at issue and that one (1) of them saw, uh, take items past the ․ last point of payment and that the other individual, the other witness, the officer, uh, took the ID and ran her name and both testified that she was the one (1) that they had interactions with.

Id. at 137–38 (emphasis added). Declaring the State's witnesses “more compelling” and observing “there is, in the Court's opinion, some bias” in Hall and her boyfriend's testimony, the trial court found the State had met its burden of proving Hall was guilty of Class A misdemeanor theft. Id. at 138. The trial court sentenced Hall to one year in county jail, all suspended if she served twenty hours of community service.

The trial court applied the proper burden of proof in finding Hall guilty of theft.

[6] Hall asserts the trial court's statement that “as the trier of fact I have to decide which set of facts is more compelling and reasonable to accept. Based on that, I do find that the State has met its burden in the case” suggests the court applied an improper, lower burden of proving guilt. Tr. Vol. 2 at 137.¹

[7] “[T]he State must prove every element of the crime charged beyond a reasonable doubt.” Carr v. State, 255 N.E.3d 519, 526 (Ind. Ct. App. 2025), trans. denied; see In re Winship, 397 U.S. 358, 364 (1970) (holding “the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which [she] is charged”). In bench trials, we presume the trial court “knows and follows the applicable law.” Laughlin v. State, 101 N.E.3d 827, 830 (Ind. Ct. App. 2018). This presumption extends to applying the correct burden of proof. Moran v. State, 622 N.E.2d 157, 159 (Ind. 1993). The presumption may be overcome if a trial court's remarks “disclose use of an erroneous standard with clarity and certainty,” id., or if the record reflects an unjustifiable risk that the court did not follow the applicable law, Cutler v. State, 249 N.E.3d 1123, 1127 (Ind. Ct. App. 2025), trans. denied.

[8] Hall compares her case to Justice v. State, 237 N.E.3d 1154 (Ind. Ct. App. 2024), trans. denied. The defendant in that case was charged with aggravated battery but argued at his bench trial that he acted in self-defense and in defense of a third party. In finding him guilty, the trial court said: “[T]he State had met its burden of proof, and I do not find that the Defendant met the burden to – for self-defense.” Id. at 1159. The defendant appealed, arguing in part that this remark showed the trial court misapplied the burden of proof. A panel of this Court was “persuaded ․ the trial court unequivocally placed on [the defendant] the burden of proving self-defense and defense of a third party” when the burden properly belonged to the State to disprove the defenses. Id. Hall argues “there is no doubt that the trial judge erroneously stated the burden of proof” in her case when he explained he found the State's evidence “more reasonable” than hers. Appellant's Br. at 10.

[9] The State points us to Moran, in which the trial court adjudicated the juvenile defendant a delinquent and stated:

Now, then, possibly if this were a criminal court where the Court was finding the juvenile guilty of a crime, that might have some difference in the decision. However, under the present circumstances, what this Court is doing is finding the juvenile guilty of being a juvenile delinquent.

622 N.E.2d at 159 (emphasis omitted). A panel of this Court held, “Clearly, the trial court thought there was a distinction between the standards of proof applicable in criminal trials and juvenile delinquency proceedings” and reversed the adjudication, concluding the trial court did not apply the reasonable doubt standard. Moran v. State, 611 N.E.2d 673, 675 (Ind. Ct. App. 1993), trans. granted. On transfer, however, the Supreme Court disagreed, holding the “questioned remarks of the judge do not disclose use of an erroneous standard with clarity and certainty sufficient to overcome the presumption” the trial court applied the correct burden of proof. Moran, 622 N.E.2d at 159–60. The Court suggested the comments “may have been made for purposes unrelated to the requisite standard of proof”—for instance, to deter “future unlawful conduct” by illustrating “the gravity of consequences that could flow from an adult criminal conviction.” Id. at 160. The State contends the trial court's remarks here, like in Moran, were not about the burden of proof.

[10] We conclude the trial court's statement here was more akin to that in Moran than in Justice. By invoking the instruction it would give jurors—an instruction about credibility and common sense—the trial court was explaining how it would evaluate the evidence as the trier of fact, not announcing a lower standard of proof. The trial court found the State's two eyewitnesses more credible than Hall and her boyfriend and based on that credibility determination, found the State had met its burden of proving Hall's guilt. The trial court's statement did not disclose use of an erroneous standard with clarity and certainty or reflect an unjustifiable risk that the court did not follow the applicable law.

Conclusion

[11] Hall has not shown the trial court's comments disclose use of an erroneous burden of proof with the clarity and certainty required to overcome the presumption the trial court followed the applicable law.

[12] Affirmed.

FOOTNOTES

1.   Hall expressly disclaims making a sufficiency of the evidence argument. See Appellant's Br. at 9.

Kenworthy, Judge.

Bradford, J., and Pyle, J., concur.