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McFadin v. State
Citations: 494 N.E.2d 983; 1986 Ind. App. LEXIS 2716Docket: No. 82A04-8601-CR33
Court: Indiana Court of Appeals; June 30, 1986; Indiana; State Appellate Court
Defendant-Appellant Craig E. McFadin appealed two convictions for leaving the scene of an accident involving property damage and injury, classified as class B misdemeanors. The court reversed the convictions, focusing solely on the sufficiency of the evidence to support the convictions. The incident involved two boys on bicycles who were struck by a red Ford pickup truck driven by an older man. Witnesses, Sandy Kneer and Kirk Pruden, observed the accident and provided descriptions of the truck and driver, including the license plate number, to Officer J.C. Wolf. The truck was registered to Lena McFadin. About 90 minutes later, Indiana State Police Officer Frank Smith stopped McFadin, who was driving the red Ford pickup matching the reported license number and description. The truck showed damage consistent with the accident. In evaluating the sufficiency of the evidence, the court noted that it does not weigh evidence or assess witness credibility but looks for substantial evidence to support guilt beyond a reasonable doubt. While a conviction can be based on circumstantial evidence, the evidence must be compelling enough to exclude every reasonable hypothesis of innocence. In this case, the court found that the State did not provide enough direct or circumstantial evidence to connect McFadin to the crime. Neither witness identified him as the driver at the time of the accident, nor did they indicate he resembled the driver. Officer Smith only testified that McFadin matched the broadcast description. The court concluded that the evidence presented was insufficient for a reasonable inference of guilt and reversed the convictions. The concurring opinion emphasized the importance of a clear statement of issues in appeals, noting McFadin's motion to correct errors was convoluted and difficult to interpret, although some concise allegations of error were identified in his brief.