Royce Love v. State

Summary

The Indiana Supreme Court held that appellate courts apply the same deferential sufficiency-of-the-evidence standard to video evidence as to other evidence, unless the video indisputably contradicts the trial court’s findings. The court concluded that the video in Royce Love’s case was incomplete and subject to interpretation, so it deferred to the trial court’s credibility and factual determinations. The court affirmed Love’s convictions for battery of a law enforcement animal and class A misdemeanor resisting law enforcement.

Holdings

1. Indiana appellate courts must apply the same deferential sufficiency-of-the-evidence standard to video evidence as to other evidence, unless the video evidence indisputably contradicts the trial court's findings.
2. The video did not indisputably contradict the trial court's findings because it was dark, incomplete, and did not show Love's exit from the vehicle, the taser deployment, or the police-dog encounter.
3. Sufficient evidence supported Love's convictions for battery to a law enforcement animal and resisting law enforcement as Class A misdemeanors.

Questions Presented

1. What standard of appellate review applies to video evidence in a sufficiency-of-the-evidence challenge?
2. Whether the video evidence indisputably contradicted the trial court's factual findings concerning Love's compliance with police and therefore required reversal of his convictions.
3. Whether the evidence was sufficient to support convictions for battery to a law enforcement animal and resisting law enforcement.

Disposition

affirmed