Summary
The Indiana Court of Appeals affirmed Paul R. Solt, Jr.'s conviction for Level 5 felony child solicitation. The court held that the evidence was sufficient to establish that Solt believed he was arranging a paid sexual encounter with a fifteen-year-old and that the State disproved his entrapment defense.
Topics
Practice areas
Questions Presented
- Whether the State presented sufficient evidence that Solt believed he was soliciting a person at least fourteen but less than sixteen years old for a sexual encounter.
- Whether the State presented sufficient evidence to disprove Solt's entrapment defense by showing that police inducement was absent.
Holdings
- The evidence was sufficient to prove beyond a reasonable doubt that Solt believed he was arranging to meet a fifteen-year-old for a paid sexual encounter.
- The State presented sufficient evidence to disprove police inducement and thereby rebut Solt's entrapment defense; the officers merely afforded Solt an opportunity to commit the offense and did not persuade him to do so.
Key quotations
“When a defendant challenges the sufficiency of the evidence to sustain a conviction or disprove a defense of entrapment, “[w]e neither reweigh the evidence nor reassess the credibility of witnesses.”” (p. 5)
“When a defendant raises an entrapment defense, the State must bear the burden of disproving one of the statutory elements beyond a reasonable doubt.” (p. 7)
“This evidence is sufficient to demonstrate that the officers did not persuade Solt to commit his offense; they merely afforded him an opportunity.” (p. 8)
Factual background
Police conducted an undercover child-solicitation sting using fake online profiles and text conversations. An undercover officer told Solt that the purported sex worker was fifteen, and Solt expressed concern about the person's age but continued communicating, agreed to drive to a hotel, and entered the designated room. After his arrest, Solt admitted that he believed he was arranging to have sex with a fifteen-year-old and claimed that the officer's eagerness and persistence overcame his judgment.
Procedural history
The State charged Solt with Level 5 felony child solicitation in the Brown Circuit Court. Solt waived a jury, proceeded to a bench trial, raised entrapment, was found guilty, and was sentenced. The Indiana Court of Appeals affirmed.