N.V., Appellant-Respondent v. State of Indiana, Appellee-Petitioner (2026)

MEMORANDUM DECISION

Case Summary

[1] N.V. appeals the juvenile court's judgment that she committed battery resulting in bodily injury. Finding sufficient evidence to support the court's judgment, we affirm.

Facts and Procedural History

[2] On May 6, 2025, fifteen-year-old A.B., a student at North Central High School, attended an after-school track practice. When practice was over, A.B. was approached by N.V., another fifteen-year-old North Central student. N.V. proceeded to hit A.B. and, after N.V. was briefly knocked to the ground, the girls exchanged several punches. N.V.’s sister ran from across the street to join in the fight and struck A.B. a few times before A.B. fell to the ground. As her sister walked away, N.V. continued to grapple with A.B. and pulled A.B.’s hair. The fight ended a few seconds later when school personnel arrived to separate the pair.

[3] On September 17, 2025, the State filed a petition alleging N.V. had committed acts constituting Class A misdemeanor battery resulting in bodily injury ¹ and Class B misdemeanor disorderly conduct.² The juvenile court held a bench trial on March 18, 2026, at which three witnesses testified. First, Washington Township Police Officer Floyd Peterson, the school's resource officer, testified that he downloaded footage of the fight from the school's security system. That footage was admitted into evidence as State's Exhibit 1.

[4] Second, A.B.’s testimony about the fight was consistent with the facts outlined above. She described suffering from several injuries, including a broken chin, chunks of hair pulled out of her scalp, and artificial nails ripped off her fingers. Photographs of A.B.’s injuries taken shortly after the fight were admitted as State's Exhibits 3-9. On cross-examination, A.B. confirmed that both N.V. and N.V.’s sister were involved in the fight, though she didn't “know for certain who hit [her] where or who did what.” Transcript at 16.

[5] Finally, John Chavis, an assistant track coach at North Central High School, testified that he saw the fight after it began and was among the personnel who ran to break it up.

[6] After the parties’ closing arguments, the juvenile court entered a true finding on the battery allegation and declined to do so on the allegation of disorderly conduct, citing substantive double jeopardy concerns. In a written order, the court adjudicated N.V. delinquent and closed her case “with no services ordered.” Appealed Order at 2. N.V. now appeals.

Discussion and Decision

[7] On appeal, N.V. contends there was insufficient evidence that she committed battery resulting in bodily injury. When reviewing a claim that a juvenile court's true finding is not supported by sufficient evidence, “we apply a ‘deferential standard of review,’ and we will ‘neither reweigh the evidence nor judge witness credibility.’ ” A.V. v. State, 228 N.E.3d 504, 509 (Ind. Ct. App. 2024) (quoting Carmack v. State, 200 N.E.3d 452, 459 (Ind. 2023)), reh'g denied, trans. denied. We consider only “the evidence and reasonable inferences supporting the verdict” and will affirm the juvenile court's judgment “if probative evidence supports each element of the crime beyond a reasonable doubt.” Id. (quoting Carmack, 200 N.E.3d at 459).

[8] To establish that N.V. committed battery as alleged, the State was required to prove that she “touche[d] another person in a rude, insolent, or angry manner,” which “result[ed] in bodily injury to any other person.” Ind. Code § 35-42-2-1 (c)(1), (d)(1) (2024) (amended 2026). N.V. only challenges the bodily injury element, arguing “[t]he State did not prove beyond a reasonable doubt that [she] caused A.B. [any] injury.” Appellant's Brief at 7.

[9] In this context, “ ‘[b]odily injury’ means any impairment of physical condition, including physical pain.” Ind. Code § 35-31.5-2-29 (2012). While the evidence was clear that A.B. suffered several injuries satisfying this definition, N.V. asserts the State failed to prove “that [she], as opposed to [her sister], caused A.B.’s injuries.” Appellant's Br. at 8. We disagree, as there was probative evidence from which the juvenile court could have reasonably inferred that N.V.’s actions resulted in A.B.’s injuries.

[10] Our Supreme Court has explained that “[a]n enhancing event that ‘results’ from a criminal act implicates proximate causation, which ‘requires that the injury would not have occurred but for the defendant's conduct.’ ” Fix v. State, 186 N.E.3d 1134, 1142 (Ind. 2022) (quoting Patel v. State, 60 N.E.3d 1041, 1052 (Ind. Ct. App. 2016)). When a criminal statute imposes an enhanced penalty if the defendant's actions resulted in bodily injury, the element of proximate causation is satisfied when bodily injury was “ ‘a natural and probable consequence’ of the defendant's criminal acts.” Id. (quoting Paragon Fam. Rest. v. Bartolini, 799 N.E.2d 1048, 1054 (Ind. 2003), abrogated on other grounds by Pennington v. Mem'l Hosp. of South Bend, Inc., 223 N.E.3d 1086, 1096 n.2 (Ind. 2024)). Whether a defendant's actions proximately caused the victim's injuries is a question for the fact-finder to resolve. See Goodwin v. Yeakle's Sports Bar & Grill, Inc., 62 N.E.3d 384, 389 (Ind. 2016).

[11] Here, the State admitted surveillance footage showing that N.V. initiated physical contact with A.B. and threw several punches before N.V.’s sister entered the fray. N.V.’s sister was only involved for a few seconds, after which N.V. continued to hit A.B. and appeared to drag A.B. by her hair as she was on the ground. It was reasonable for the juvenile court to conclude that N.V.’s actions proximately caused A.B.’s injuries, given that N.V. started the fight, threw most of the punches, and pulled A.B.’s hair after she fell to the ground. N.V.’s argument to the contrary is merely a request to reweigh the evidence, which we will not do.

Conclusion

[12] For these reasons, we find sufficient evidence supporting the juvenile court's finding that N.V. committed battery resulting in bodily injury. We therefore affirm the court's judgment.

[13] Affirmed.

FOOTNOTES

1.   Ind. Code § 35-42-2-1(c)(1), (d)(1) (2024) (amended 2026).

2.   Ind. Code § 35-45-1-3(a)(1) (2014).

DeBoer, Judge.

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