Jada Trainor, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Statement of the Case

[1] After causing a ruckus at the hospital where she was seeking treatment, Jada Trainor resisted a law enforcement officer's attempts to arrest her. A jury convicted Trainor of resisting law enforcement. Trainor now appeals, raising one issue for our review: Whether the State presented sufficient evidence at trial to support Trainor's conviction for resisting law enforcement.

[2] We affirm.

Facts and Procedural History

[3] On July 13, 2024, Trainor visited the emergency department of an Indianapolis, Indiana hospital to receive treatment for flu symptoms. After sitting in the waiting room for approximately one hour, Trainor approached the registration station and began yelling at the nurses about how long she had been waiting. The nurses asked Trainor to go to a patient room which they made available to her after she started complaining. Trainor refused to go to her assigned room, telling the nurses she was “not f[*]cking going anywhere,” Tr. Vol. III at 37. In addition to yelling and cursing, Trainor knocked down signs from a nearby wall, so a nurse called security. Approximately one minute later, three Marion County Sheriff's Department Deputies, including Deputy Anthony Sisco, arrived to address the situation. While the record is not clear, it appears at least Deputy Sisco and possibly the other two deputies wore equipment belts which contained a radio, taser, firearm, and handcuffs.

[4] Deputy Sisco approached Trainor and asked how he could help. Trainor disregarded Deputy Sisco and continued to yell at the nurses. Deputy Sisco told Trainor that she needed to step outside with him to discuss the situation. Trainor ignored him, so Deputy Sisco placed his hand with a “light touch” on Trainor's shoulder and gestured for her to walk toward the exit. Tr. Vol. III at 97. Trainor then allegedly turned and struck Deputy Sisco's arm with her fist, so Deputy Sisco told Trainor she was getting arrested for battering a law enforcement officer. Trainor responded, “[N]o I'm f[*]cking not” and attempted to pull away. Id. at 98. After Deputy Sisco told Trainor again that she was being arrested, she fought and pushed back against Deputy Sisco. Two other deputies assisted Deputy Sisco in bringing Trainor to the ground. While on the ground, Trainor flailed her right arm and kicked her legs. Deputy Sisco placed his taser on the small of Trainor's back and warned her, “[G]ive me your arms or you will be tased.” Id. at 101.

[5] Shortly after issuing the warning, Deputy Sisco determined he could gain control of Trainor's arm without using the taser. While attempting to holster his taser, Deputy Sisco felt a “grab” on his firearm. Tr. Vol. III at 101. Deputy Sisco told the other two deputies that Trainor was “attempting to grab [his] gun.” Id. With assistance from another deputy, Deputy Sisco successfully placed Trainor in handcuffs. Deputy Sisco placed Trainor in a wheelchair and wheeled her to a holding cell. While Trainor was in the holding cell, a nurse offered Trainor medical services, but Trainor refused because “people had just watched [her be] beaten by officers” and “she didn't want to be around any nurses or police.” Tr. Vol. III at 144.

[6] The State charged Trainor with disarming law enforcement as a Level 5 felony,¹ battery against a public safety official as a Level 6 felony,² and resisting law enforcement as a Class A misdemeanor ³ . A jury found Trainor guilty of resisting law enforcement as a Class A misdemeanor and not guilty of the other two charges. The trial court sentenced Trainor to 365 days of incarceration, other than credit days, all suspended to probation. This appeal ensued.

Discussion and Decision

The State Presented Sufficient Evidence to Support Trainor's Conviction

[7] Trainor argues that the State presented insufficient evidence at trial to support her conviction for resisting law enforcement as a Class A misdemeanor. Our standard of review for such a claim is as follows:

“A conviction is supported by sufficient evidence if ‘there is substantial evidence of probative value supporting each element of the offense such that a reasonable trier of fact could have found the defendant guilty beyond a reasonable doubt.’ ” Hancz-Barron v. State, 235 N.E.3d 1237, 1244 (Ind. 2024) (quoting Willis v. State, 27 N.E.3d 1065, 1066 (Ind. 2015)). This Court reviews only the evidence most favorable to the verdict and the reasonable inferences therefrom, and will reverse only where it is shown that “no reasonable fact-finder could find the elements of the crime proven beyond a reasonable doubt.” Teising [v. State], 226 N.E.3d [780,] 783 [(Ind. 2024)].

Konkle v. State, 253 N.E.3d 1068, 1090–91 (Ind. 2025). We do not reweigh the evidence or reassess witness credibility. Id. at 1090 (quoting Teising, 226 N.E.3d at 783).

[8] In order to convict Trainor of resisting law enforcement as a Class A misdemeanor, the State had to prove beyond a reasonable doubt that Trainor knowingly or intentionally forcibly resisted Deputy Sisco while Deputy Sisco was lawfully engaged in the execution of his duties. Ind. Code § 35-44.1-3-1(a)(1) (effective July 1, 2024, to June 30, 2025). Trainor argues that there was insufficient evidence to prove that she “knew or had reason to know [Deputy] Sisco was a law enforcement officer.” Appellant's Br. at 10. In support thereof, Trainor contends first, there is no evidence of Deputy Sisco identifying himself, either verbally or visually, as law enforcement and second, evidence of Deputy Sisco being armed during the arrest does not demonstrate Trainor knew that Deputy Sisco was law enforcement.

[9] To support a resisting law enforcement conviction, the State must demonstrate that the defendant knew or had reason to know that the person arresting her was a law enforcement officer. Mason v. State, 944 N.E.2d 68, 71 (Ind. Ct. App. 2011) (citing Eberle v. State, 942 N.E.2d 848, 858 (Ind. Ct. App. 2011), trans. denied), trans. denied. This court has held that evidence of an officer wearing full uniform and identifying himself as law enforcement is sufficient for a jury to find that a person knew she was being arrested by a law enforcement officer. Blackmon v. State, 47 N.E.3d 1225, 1239 (Ind. Ct. App. 2015).

[10] Here, the probative evidence and reasonable inferences supporting the verdict show that Trainor knew or had reason to know Deputy Sisco was a law enforcement officer. While the record does not explicitly state Deputy Sisco wore a uniform, there is evidence in the record that suggests Deputy Sisco wore law enforcement related items. When Deputy Sisco first approached Trainor, he was wearing an equipment belt with a radio, taser, handcuffs, and firearm. A reasonable jury could infer that Deputy Sisco's equipment belt with lethal and nonlethal weapons communicated to Trainor that Deputy Sisco was a law enforcement officer.

[11] Deputy Sisco also identified himself as a law enforcement officer when he attempted to arrest Trainor. Specifically, after Trainor allegedly punched Deputy Sisco, he said he was arresting Trainor for battery on a law enforcement officer. Upon hearing that she was being arrested, Trainor pulled away from Deputy Sisco. Deputy Sisco informed Trainor again that she was being placed under arrest, and she fought and pushed against Deputy Sisco to avoid being placed in handcuffs. Deputy Sisco warned Trainor that if she did not comply, he would tase her. Deputy Sisco then placed Trainor in handcuffs. The jury could reasonably conclude that Trainor knew that Deputy Sisco was a law enforcement officer based on her response to Deputy Sisco identifying himself as law enforcement and his use of his equipment during the arrest.

[12] Additionally, Trainor does not claim that she did not know Deputy Sisco was a law enforcement officer at the time of the incident, or during trial. After being placed under arrest, Trainor refused medical care because she did not want people to see her after being “beaten by officers.” Tr. Vol. III at 144. Trainor testified to being placed in handcuffs and referred to the deputies as officers during her testimony. Based on the foregoing and the lack of any evidence that Trainor did not know the officers were law enforcement, the State presented sufficient evidence at trial to support Trainor's conviction for resisting law enforcement. We therefore affirm Trainor's conviction.

[13] Affirmed.

FOOTNOTES

1.   Ind. Code § 35-44.1-3-2(b).

2.   I.C. § 35-42-2-1(c)(1), (e)(2).

3.   I.C. § 35-44.1-3-1(a)(1) (effective July 1, 2024, to June 30, 2025).

Felix, Judge.

Tavitas, C.J., and Bradford, J., concur