William C. Allen, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Statement of the Case

[1] While in a long-term relationship with Angela Whitley, William Allen punched Angela's daughter Brandi Hughes in the mouth. Brandi's father Jeffrey Hughes attempted to intervene, and Allen struck Jeffrey with a thermos and pushed him to the ground. During a bench trial, Allen moved for involuntary dismissal under Indiana Trial Rule 41(B). The trial court denied the motion and convicted Allen of battery resulting in moderate bodily injury to Jeffrey and battery resulting in bodily injury to Brandi. Allen now appeals, raising two issues for our review, which we revise and restate as the following single issue: Whether the State presented sufficient evidence at trial to support Allen's conviction for battery resulting in moderate bodily injury.

[2] We affirm

Facts and Procedural History

[3] In July 2024, Brandi was providing home-health care for Jeffrey and Whitley in Marion County, Indiana. On July 5, Brandi took her parents to the store, and when they returned to Whitley's house, Brandi overheard Allen make a comment about her “biracial kids,” so she asked him about that. Tr. Vol. II at 20. Allen became “very mad” and “very aggressive,” and he punched Brandi in the mouth. Id. A fistfight erupted between Brandi and Allen; the two were “going around like a hurricane in the kitchen,” id. at 9. When Jeffrey tried to intervene, Allen hit him with “a big thermos.” Id. Brandi saw the thermos in Allen's hand and believed he was going to hit Whitley with it next, so she knocked it out of Allen's hand. Jeffrey pushed Allen and told him to “knock it off.” Id. at 10. Allen pushed Jeffrey back, sending him “flying across the room,” id. at 22. Brandi saw Jeffrey lying on the floor bleeding and put Allen in a chokehold. After Jeffrey told her to “let [Allen] loose,” id. at 10, Brandi let go of Allen, and he left the house. Jeffrey was “bleeding everywhere” and had lacerations with skin “hanging down” on both arms. Id. at 23.

[4] The State charged Allen with two counts of battery against Jeffrey—one count as a Level 6 felony ¹ and one count as a Class A misdemeanor ² —plus one count of battery against Brandi as a Class A misdemeanor ³ . After the close of the State's evidence at his bench trial, Allen moved for an involuntary dismissal under Trial Rule 41(B), and the trial court denied his motion. Allen did not present any evidence in his defense. The trial court found Allen guilty as charged and entered judgments of conviction for the Level 6 felony and the Class A misdemeanor concerning Brandi.⁴ The trial court sentenced Allen to a total of 545 days of incarceration, all suspended to probation. This appeal ensued.⁵

Discussion and Decision

The State Presented Sufficient Evidence to Support Allen's Conviction

[5] Allen challenges his conviction for battery resulting in moderate bodily injury as a Level 6 felony on two fronts: (1) he contends the trial court erred by denying his Trial Rule 41(B) motion, and (2) he argues the State did not present sufficient evidence to support this conviction. “In a criminal action, the defendant's Trial Rule 41(B) motion is essentially a test of the sufficiency of the State's evidence.” Ball v. State, -- N.E.3d --, 2026 WL 1379192, at *4 (Ind. Ct. App. 2026) (citing Helms v. State, 926 N.E.2d 511 (Ind. Ct. App. 2010)), trans. not sought. Therefore, if we conclude sufficient evidence supports Allen's conviction, then we need not separately address his argument regarding the denial of his Trial Rule 41(B) motion. See Bowyer v. Ind. Dep't Nat. Res., 944 N.E.2d 972, 992 n.18 (Ind. Ct. App. 2011) (citing F.D. Borkholder Co. v. Sandock, 413 N.E.2d 567, 569 n.2 (Ind. 1980)) (explaining that if sufficient evidence supports the verdict, there is no need for this court to separately discuss propriety of T.R. 41(B) motion denial). We thus review Allen's two challenges simultaneously.

[6] Allen argues that the State presented insufficient evidence at trial to support his conviction for battery resulting in moderate bodily injury as a Level 6 felony. 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).

[7] In order to convict Allen of battery resulting in moderate bodily injury as a Level 6 felony, the State had to prove beyond a reasonable doubt that he knowingly or intentionally touched Jeffrey in a “rude, insolent, or angry manner,” resulting in moderate bodily injury to Jeffrey. Ind. Code § 35-42-2-1(c)(1), (e)(1) (effective July 1, 2024, to June 30, 2026). Allen specifically argues that the State presented insufficient evidence to prove that he was the person who caused Jeffrey's injuries. A conviction can be sustained on the uncorroborated testimony of a single witness, even if the witness is the victim. Chambless v. State, 119 N.E.3d 182, 193 (Ind. Ct. App. 2019) (citing Bailey v. State, 979 N.E.2d 133, 135 (Ind. 2012)), trans. denied.

[8] Here, Jeffrey testified that Allen hit him with “a big thermos,” Tr. Vol. II at 9, and pushed him. Jeffrey's testimony alone was sufficient to prove that Allen pushed him and caused his injuries. See Chambless, 119 N.E.3d at 193 (citing Bailey, 979 N.E.2d at 135). Nevertheless, Allen argues it was unreasonable for the trial court to conclude he was the one who caused Jeffrey's injuries because Brandi's and Jeffrey's testimony was contradictory regarding the timeline of the fight. This argument is merely a request for us to reweigh the evidence and reassess witness credibility, which we cannot do. Konkle, 253 N.E.3d at 1090–91 (quoting Teising, 226 N.E.3d at 783). The probative evidence and reasonable inferences supporting the verdict show that Allen is the person who hit and pushed Jeffrey, thereby causing Jeffrey's injuries. While Brandi did not see Allen push Jeffrey, she testified that she “[did not] know who else could have pushed him.” Tr. Vol. II at 22. A reasonable factfinder could reasonably conclude that Allen hit and pushed Jeffrey.

[9] Based on the foregoing, the State presented sufficient evidence to support Allen's conviction for battery resulting in moderate bodily injury as a Level 6 felony. Accordingly, the trial court did not err by denying Allen's Trial Rule 41(B) motion. We therefore affirm the trial court on all issues raised.

[10] Affirmed.

FOOTNOTES

1.   Ind. Code § 35-42-2-1(c)(1), (e)(1) (effective July 1, 2024, to June 30, 2026).

2.   I.C. § 35-42-2-1(c)(1), (d)(1) (effective July 1, 2024, to June 30, 2026).

3.   I.C. § 35-42-2-1(c)(1), (d)(1) (effective July 1, 2024, to June 30, 2026).

4.   Due to double jeopardy concerns, the trial court vacated the Class A misdemeanor conviction concerning Jeffrey.

5.   Allen's record citations—which generally take the form of “V.II 32”—do not indicate whether he is citing to the Transcript or Appendix, as required by Indiana Appellate Rule 22(C). See Ind. Appellate Rule 46(A)(5), (6)(a), (8)(a) (requiring record citations comply with App. R. 22(C)). We remind counsel that the purpose of our appellate rules “is to aid and expedite review and to relieve the appellate court of the burden of searching the record and briefing the case.” Miller v. Patel, 212 N.E.3d 639, 657 (Ind. 2023) (quoting Dridi v. Cole Kline LLC, 172 N.E.3d 361, 364 (Ind. Ct. App. 2021)). Additionally, in his Conclusion, Allen requests relief for “Matthew Ball,” Appellant's Br. at 18, who is not a party to this case. Because Allen's noncompliance with our Appellate Rules does not substantially impede our review of his claims, we choose to address their merits. See Pierce v. State, 29 N.E.3d 1258, 1267 (Ind. 2015).

Felix, Judge.

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