Isaiah D. Williams, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] Isaiah Williams appeals his conviction for reckless driving, arguing it was not supported by sufficient evidence. Finding the evidence was sufficient, we affirm.

Facts and Procedural History

[2] Shortly after 5:30 p.m. on June 3, 2025, Evansville Police Officer Aaron Hadley was driving west on Lloyd Expressway. He turned north onto Burkhart Road and saw a green Dodge Charger and a red Chevrolet Corvette sitting at a red light waiting to turn east onto Lloyd. The Corvette's windows were down, so Hadley got a good look at the driver, who was “a black male with facial stubble, appearing to be in his mid to late 30s or so.” Transcript at 18. Hadley did a U-turn at the next intersection and drove back toward the Charger and Corvette, which were still waiting at the red light. He saw the Corvette had a temporary plate from a dealership, though he was only able to take note of part of the license plate number.

[3] Once the light turned green, the Charger and Corvette “turned east onto the expressway, and ․ both rapidly accelerated to high rates of speed, passing all the traffic around them.” Id. at 19. Hadley watched as the vehicles “weaved across ․ three lanes to maneuver around slower vehicles ․ so they could continue to drive faster[.]” Id. And he “could ․ hear the engines of both [cars] revving as they continued to accelerate.” Id. He pursued the vehicles and managed to stop the Charger, but not the Corvette, which “had already passed Interstate 69 and was entering Warrick County[.]” Id. at 20.

[4] The Charger was driven by a woman named Jessica Cottone. Later, Hadley learned that Cottone had recently purchased a red Corvette that had a temporary plate consistent with the partial plate number he noted on June 3. Hadley searched for that vehicle in the police database and saw that Williams had been pulled over while driving it two weeks earlier. Hadley then searched Williams’ driving record and recognized him from his driver's license photograph as “the same person that [Hadley] had seen behind the wheel of the Corvette ․” Id. at 21. After Hadley identified Williams as the driver, on June 13, 2025, the State charged Williams with Count I: Engaging in a Motor Vehicle Speed Contest, a Class B misdemeanor;¹ Count II: Reckless Driving, as a Class C misdemeanor;² and Count III: Reckless Driving, as a Class C misdemeanor.³

[5] On December 17, the trial court held a bench trial at which Willams represented himself. Before presenting evidence, the State moved to dismiss Count III, which the trial court granted. The State then called Hadley as its sole witness, and he testified about seeing Williams drive the Corvette on June 3 in the manner described above. When asked to describe Lloyd Expressway and its intersection with Burkhart Road at the time of the incident, Hadley said, “Traffic was very heavy with rush hour traffic. All three lanes were filled, and that's a busy intersection as is, and it was very congested.” Id. at 19. He explained that despite this congestion, traffic was moving “at around the speed limit of 50 miles per hour” and Williams and Cottone “were going faster than that[.]” Id. at 20. Hadley did not use a speed measuring device to record the vehicles’ speeds, and though he was trained to visually estimate speed, Williams and Cottone “were moving so fast” that “[i]t was difficult for [him] to visualize exactly how fast they were going[.]” Id. However, Hadley testified that Williams was driving at such a high rate of speed that he managed to pass Cottone (who was also speeding) and take off into the adjacent county “within seconds” of turning onto Lloyd. Id.

[6] After Williams briefly cross-examined Hadley, the State rested its case and Williams testified in his own defense. Williams admitted during his cross-examination that he had been driving the Corvette on June 3. When the trial court asked Williams if he wanted to have the “final word[,]” Williams said he and Cottone were not racing, and he was driving the Corvette “to her crib and dropping it off” after taking it for repairs earlier that day. Id. at 29. Williams then rested his case.

[7] In closing, the State argued that Hadley's inability to visually estimate Williams’ speed was a testament to “how fast [Williams was] moving” and added,

[Williams and Cottone] were both accelerating through congested traffic․ [T]he real telling thing is he was moving faster than her, and the officer said it all happened within seconds. The officer was able to stop ․ Cottone, but he didn't even have a chance to stop [Williams], he was moving so fast that he [had] basically gone into Warrick County at that time. So I think that's indicative of the acceleration, and then you've got the endangerment factor with all the congested traffic and people having -- these two cars weaving in and out.

Id. at 30. In his closing argument, Williams argued that Hadley's testimony that all three lanes were congested cut against the State's allegation that he and Cottone were engaged in a speed contest. Specifically, he claimed “it's hard to try to have a motor speed contest with all three lanes going.” Id. at 31. As for Hadley's testimony that Williams was driving at a high rate of speed, Williams argued,

he literally said it was based off ․ the sound of the engine. You can start it up and still hear it. Yes, you can rev it in neutral, ․ going nowhere, and you can still hear that engine. There's not a time that you won't hear a V8 Scat pack and V8 Corvette sounding off, especially when you have aftermarket parts done to the exhaust system[.]

Id.

[8] After hearing the parties’ arguments, the trial court found Williams not guilty of engaging in a speed contest under Count I and guilty of reckless driving under Count II. It entered a judgment of conviction accordingly and imposed a sixty-day suspended sentence. Williams now appeals.

Discussion and Decision

[9] Williams argues “[t]he State failed to prove that [he] was driving recklessly as defined by statute.” Appellant's Brief at 7. When reviewing a challenge to the sufficiency of the evidence, we are mindful that it is the fact-finder's role, not ours, “to assess witness credibility and weigh the evidence to determine whether it is sufficient to support a conviction.” Teising v. State, 226 N.E.3d 780, 783 (Ind. 2024) (quoting Drane v. State, 867 N.E.2d 144, 146 (Ind. 2007)). Additionally, “[w]e consider only the evidence most favorable to” the conviction, together with any reasonable inferences that can be drawn from that evidence. Id. We will affirm a conviction unless no reasonable fact-finder could have found “the elements of the crime proven beyond a reasonable doubt.” Id. (quoting Jenkins v. State, 726 N.E.2d 268, 270 (Ind. 2000)).

[10] To convict Williams of reckless driving as alleged here, the State had to prove he “operate[d] a vehicle and ․ recklessly ․ [drove] at such an unreasonably high rate of speed ․ under the circumstances as to ․ endanger the safety or the property of others[.]” Ind. Code § 9-21-8-52(a)(1)(A) (2019).⁴ Williams does not challenge the recklessness element and focuses instead on whether he drove at an unreasonably high rate of speed as to endanger the safety or property of others. We note, however, that his three-sentence argument regarding the endangerment element lacks citations to the record or supporting authority and does not comply with Appellate Rule 46(A)(8)(a), which requires appellants to support each argument with “cogent reasoning” and “citations to the authorities, statutes, and the Appendix or parts of the Record on Appeal relied on[.]” Williams has therefore waived his endangerment argument, and we focus our analysis on whether there was sufficient evidence that he drove at an unreasonably high rate of speed. See Martin v. Brown, 129 N.E.3d 283, 285 (Ind. Ct. App. 2019) (“Failure to present a cogent argument results in waiver of the issue on appeal.”).

[11] Williams contends there was insufficient evidence that he drove at an unreasonably high rate of speed because Hadley “did not know how fast Williams was driving and was only able to testify that it was faster than the flow of traffic.” Appellant's Br. at 7. And he cites three cases which he suggests require the State to prove a defendant's exact speed to obtain a reckless driving conviction. But those cases do not support that contention and are inapposite.

[12] First, in Crussel v. State, the defendant was measured by police radar driving ninety-one miles per hour in a fifty-five mile-per-hour zone. 29 N.E.3d 746, 748 (Ind. Ct. App. 2015). The defendant challenged his resulting reckless driving conviction on appeal but, critically for our purposes, did not “challenge the elements that he recklessly drove his car at an unreasonably high rate of speed.” Id. at 749. Thus, the Crussel panel only analyzed the endangerment element, which is not at issue here since Williams waived his endangerment argument. To support the finding of endangerment, the panel did not hold that the State is required to prove a defendant's exact speed but merely relied on the defendant's speed in light of other circumstances. See id. at 751-52 (“[I]t was reasonable for the trial court ․ to have drawn an inference that [the defendant] endangered the safety and property of others from the evidence that [he] drove his car ninety-one miles per hour in a fifty-five mile-per-hour zone in the dark of night on a country road that had houses and cross streets ․”).

[13] Second, Williams’ reliance on Coy v. State, 999 N.E.2d 937 (Ind. Ct. App. 2013) fares no better. There, the defendant was convicted of one count of reckless homicide and two counts of criminal recklessness after driving “as fast as 106 miles per hour before losing control of the car and crashing it into a group of trees on the side of the road, killing one passenger ․ and seriously injuring [two] other[s] ․” Id. at 940. Not only did the defendant not challenge the sufficiency of those convictions on appeal, but his speed was relevant only to the panel's review of the appropriateness of his sentence under Appellate Rule 7(B). Id. at 948-49. We fail to see what relevance Coy has to Williams’ circumstances, especially since the only reason the panel discussed the reckless driving statute was to determine whether the trial court should have instructed the jury on reckless driving as a lesser included offense of reckless homicide. See id. at 942-45.

[14] Finally, although Magee v. State, 523 N.E.2d 432 (Ind. Ct. App. 1988) is more on point, it does not support Williams’ position. There, the panel affirmed the defendant's conviction under a prior version of the reckless driving statute that was substantively similar to the current one, reasoning the defendant

was driving 40 miles per hour over the speed limit, failed to come to a complete stop at two stop signs, popped a wheelie for 20 feet, and would not have been able to stop suddenly if he was required to do so. [The defendant] also testified himself that he drove his motorcycle even though he was aware that his clutch was broken. This evidence reasonably supports the inference that [the defendant] operated his motorcycle in a reckless manner that endangered the safety or property of others, and thus supports [his] conviction for reckless driving.

Id. at 434-35. Far from supporting Williams’ claim that the State must prove a defendant's exact speed, the Magee panel merely mentioned the defendant's exact speed as one piece of evidence, among others, that supported a finding that he drove at an unreasonably high rate of speed. While other panels of this Court have relied on defendants’ excessive speeding to affirm reckless driving convictions,⁵ the State is right that no Indiana appellate court has held that “[e]xact evidence of the driver's speed is ․ required ․” Appellee's Br. at 6.

[15] Indeed, had the legislature wanted to make the defendant's exact speed an element of the offense, it could have specified as much in the reckless driving statute. Instead, it used the phrase “unreasonably high rate of speed ․ under the circumstances” to define the prohibited conduct. I.C. § 9-21-8-52(a)(1) (emphasis added). Williams is right to suggest that a “substantial differential between the speed of [a defendant's] vehicle and the speed limit” is one circumstance that may make a defendant's speed unreasonable. Taylor v. State, 457 N.E.2d 594, 598 (Ind. Ct. App. 1983). However, there is nothing in the statute foreclosing the notion that even a slight deviation above the speed limit (or, for that matter, above the flow of traffic) may be unreasonable in light of other circumstances—including traffic congestion, the condition of the roadway, the time of day, weather conditions, the defendant's familiarity with the area, or a whole host of other factors that may render a defendant's speed unreasonable.

[16] Here, the evidence showed that Williams was driving significantly faster than other cars on the roadway (which were driving at or near the posted speed limit of fifty miles per hour) and weaved in and out of congested rush hour traffic so he could continue to accelerate. Williams’ request for us to second-guess the trial court's determination that his speed was unreasonably high under those circumstances is merely a request to reweigh evidence, which we will not do. See Crussel, 29 N.E.3d at 752. To be clear, Williams is correct that driving “ ‘[f]aster than fifty miles per hour’ in a fifty mile an hour zone is not per se ․ unreasonabl[e] ․” Appellant's Br. at 9. But we affirm Williams’ conviction because there was probative evidence from which the trial court could have inferred that he drove much faster than other cars on the roadway and at a rate of speed that was unreasonable given the traffic conditions.

Conclusion

[17] For these reasons, we affirm Williams’ conviction.

[18] Affirmed

FOOTNOTES

1.   Ind. Code §§ 9-21-6-1 (1991), 9-21-6-3 (2008).

2.   Ind. Code § 9-21-8-52(a)(1) (2019)

3.   I.C. § 9-21-8-52(a)(3).

4.   Alternatively, the State could have secured a conviction if it proved Williams recklessly drove at an unreasonable rate of speed and “block[ed] the proper flow of traffic[.]” I.C. § 9-21-8-52(a)(1)(B). However, the State's argument on appeal focuses on whether Williams endangered the safety or property of others.

5.   For example, in Taylor v. State, the panel reasoned that “[a]lthough the legislature elected not to define ‘unreasonably high rate of speed,’ it is clear that driving forty miles per hour in excess of the speed limit is unreasonable and reckless.” 457 N.E.2d 594, 598 (Ind. Ct. App. 1983).

DeBoer, Judge.

Mathias, J., and Kenworthy, J., concur.