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Brian Bassett v. State of Indiana (mem. dec.)

Citation: Not availableDocket: 49A02-1710-CR-2212

Court: Indiana Court of Appeals; May 4, 2018; Indiana; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, the appellant challenged his conviction for Class B misdemeanor public intoxication under Indiana Code section 7.1-5-1-3(a)(4). The conviction arose from an incident where the appellant was found intoxicated on church steps, displaying signs of severe intoxication. The primary legal issue was whether the appellant's behavior caused harassment, annoyance, or alarm to another person. Officer Jamal Abdullah, the sole witness at trial, testified about the appellant's condition, noting that it alarmed him and prompted a call for medical assistance. The trial court found the testimony sufficient and convicted the appellant, sentencing him to 180 days, with most of the sentence suspended to probation. The appellant contended that the evidence was insufficient to prove the statutory requirement of causing distress to another individual. However, the appellate court upheld the conviction, emphasizing the presumption of the trial court's decision's legitimacy and the sufficiency of the evidence standard, which requires only a reasonable inference supporting the verdict. The court affirmed the conviction, noting that the trial judge is presumed to correctly understand and apply the law, and the limited evidence was adequate to sustain the guilty verdict.

Legal Issues Addressed

Judicial Presumption in Bench Trials

Application: The court noted that judges in bench trials are presumed to know and apply the law correctly, and this presumption supported the trial court's findings.

Reasoning: The court disagreed, noting that judges in bench trials are presumed to know and apply the law correctly.

Public Intoxication under Indiana Code Section 7.1-5-1-3(a)(4)

Application: The court affirmed the conviction as evidence showed that the defendant's intoxicated condition caused distress to another person, meeting the statutory requirements.

Reasoning: The State charged Bassett with public intoxication, citing his behavior as causing distress to another individual.

Role of Officer Testimony in Establishing Distress

Application: The testimony of Officer Abdullah, who was alarmed by the defendant's condition, was deemed sufficient to establish the distress element required under the statute.

Reasoning: During Bassett’s bench trial, Officer Abdullah confirmed he was alarmed by Bassett’s condition, which the State used as part of its evidence.

Sufficiency of Evidence in Public Intoxication Cases

Application: The court upheld the conviction based on the presumption of legitimacy of the trial court's decision, emphasizing that evidence need only permit a reasonable inference supporting the verdict.

Reasoning: In reviewing the sufficiency of the evidence, the court emphasized the presumption of legitimacy of the trial court's decision and the standard that evidence need only permit a reasonable inference supporting the verdict.