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

CourtIndiana Court of Appeals
DecidedDecember 26, 2018
Docket18A-CR-1416
StatusPublished

This text of Brian Valenti v. State of Indiana (mem. dec.) (Brian Valenti v. State of Indiana (mem. dec.)) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brian Valenti v. State of Indiana (mem. dec.), (Ind. Ct. App. 2018).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision shall not be FILED regarded as precedent or cited before any Dec 26 2018, 9:09 am

court except for the purpose of establishing CLERK Indiana Supreme Court the defense of res judicata, collateral Court of Appeals and Tax Court estoppel, or the law of the case.

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Chris M. Teagle Curtis T. Hill, Jr. Muncie, Indiana Attorney General of Indiana Matthew Koressel Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Brian Valenti, December 26, 2018 Appellant-Defendant, Court of Appeals Case No. 18A-CR-1416 v. Appeal from the Blackford Superior Court State of Indiana, The Honorable John N. Barry, Appellee-Plaintiff. Judge Trial Court Cause No. 05D01-1802-CM-54

Bailey, Judge.

Court of Appeals of Indiana | Memorandum Decision 18A-CR-1416 | December 26, 2018 Page 1 of 7 Case Summary [1] Brian Valenti (“Valenti”) appeals his conviction for resisting law enforcement,

as a Class A misdemeanor,1 following a jury trial. He raises one issue for our

review which we restate as whether the State presented sufficient evidence to

support his conviction.

[2] We affirm.

Facts and Procedural History [3] The evidence supporting the judgment is as follows. Shortly after three o’clock

in the morning on February 21, 2018, Blackford County Sheriff’s Department

Deputy Tyler Ingram (“Dep. Ingram”) was getting fuel at a service station in

Hartford City, Indiana, when he observed a gray Lexus that appeared not to

have any headlights on drive through the station’s parking lot at a fairly high

rate of speed. Ingram entered his marked police car, activated his red and blue

lights and siren, and followed the Lexus in order to conduct a traffic stop. The

Lexus continued driving for approximately three blocks and then stopped in

front of a residence that was later proved to be Valenti’s home.

[4] Dep. Ingram exited his vehicle, approached the Lexus, and recognized the

driver as Valenti. Dep. Ingram was wearing a body camera that recorded his

1 Ind. Code § 35-44.1-3-1(a)(1).

Court of Appeals of Indiana | Memorandum Decision 18A-CR-1416 | December 26, 2018 Page 2 of 7 entire encounter with Valenti.2 Dep. Ingram observed that Valenti’s eyes were

red and glossy and that he seemed “tense” and “agitated.” Tr. at 31. Dep.

Ingram instructed Valenti to place his hands on his steering wheel, and Valenti

did so. Dep. Ingram informed Valenti that he wanted to perform some sobriety

tests on Valenti. Because it was dark and raining, Dep. Ingram requested that

Valenti accompany him to the police station to do the sobriety tests, but Valenti

refused that request. Dep. Ingram ordered Valenti out of his vehicle and

Valenti complied.

[5] Dep. Ingram conducted the horizontal gaze nystagmus test on Valenti, and

Valenti failed that test. During the testing, Valenti was “vocally displeased”

with the situation and was using profanity and “making demands” in a tone of

voice that was “louder than necessary.” Id. at 34. After the first test, Valenti

refused Dep. Ingram’s request to conduct additional sobriety tests; instead,

Valenti “[d]emanded a blood draw, to go to the hospital, a breathalyzer test,

and a supervisor.” Id. at 35.

[6] After Hartford City Police Department officer Lucas Phillips (“Officer

Phillips”) and one other police officer arrived at the scene to assist, Dep.

Ingram gave Valenti “several commands” to put his hands behind his back so

that the police could handcuff him. Id. at 57. Valenti did not comply with

2 Although the video recording from the body camera is in evidence and in the record as State’s Exhibit 1, it only recorded Valenti from the neck up. And, because it was dark and raining, the recording’s visibility is poor.

Court of Appeals of Indiana | Memorandum Decision 18A-CR-1416 | December 26, 2018 Page 3 of 7 those commands; rather, he continued to be “verbally aggressive.” Id. at 36.

Therefore, Dep. Ingram restrained Valenti’s right arm and Officer Phillips

restrained Valenti’s left arm in order to put Valenti’s hands behind his back.

When Dep. Ingram put his hands on Valenti, he felt Valenti’s body tense and

felt Valenti “pulling away from [him] as if to escape [his] grasp.” Id. at 45.

Officer Phillips also felt Valenti tense when he grabbed his left arm. Valenti

was “actively struggling,”3 and Officer Phillips had to “forcibly put [Valenti’s

left hand] behind his back in an effort to apply handcuffs.” Id. at 57. When the

officers were unable to apply handcuffs while Valenti was standing, they

lowered Valenti to the ground and, with “additional effort,” Id. at 58, and

“struggle,” Id. at 45, placed Valenti in handcuffs.

[7] On February 22, 2018, the State charged Valenti with resisting law

enforcement, as a Class A misdemeanor; disorderly conduct, as a Class B

misdemeanor;4 and operating a vehicle while intoxicated, as a Class C

misdemeanor.5 Valenti’s jury trial took place on May 16. Dep. Ingram and

Officer Phillips testified at the trial, as did Valenti’s neighbor, Gary Glancy

(“Glancy”), who witnessed the events surrounding Valenti’s arrest on February

21. The jury found Valenti guilty of resisting law enforcement as charged and

3 The audio recording from the body camera reflects the sounds of struggle at that point, but the video does not provide a clear view of Valenti and the officers. State’s Ex. 1. 4 I.C. § 35-45-1-3(a)(1). 5 I.C. § 9-30-5-2(a).

Court of Appeals of Indiana | Memorandum Decision 18A-CR-1416 | December 26, 2018 Page 4 of 7 not guilty of the other charges against him. On June 14, the trial court entered

its judgment of conviction and imposed a three hundred sixty-five day sentence

with four days of credit time. This appeal ensued.

Discussion and Decision [8] Valenti contends that the evidence is insufficient to support his resisting law

enforcement conviction. Our standard of review in a sufficiency of the evidence

claim is clear:

[W]e examine only the probative evidence and reasonable inferences that support the [judgment]. We do not assess witness credibility, nor do we reweigh the evidence to determine if it was sufficient to support a conviction. Under our appellate system, those roles are reserved for the finder of fact. Instead, we consider only the evidence most favorable to the trial court ruling and affirm the conviction unless no reasonable fact-finder could find the elements of the crime proven beyond a reasonable doubt.

Lock v. State, 971 N.E.2d 71, 74 (Ind. 2012) (citations and quotation marks

omitted).

[9] Valenti argues that there was insufficient evidence that he forcibly resisted law

enforcement. Under Indiana Code Section 35-44.1-3-1(a)(1), “[t]he basic

offense of resisting law enforcement has five essential elements: that [the

defendant] (1) knowingly or intentionally (2) forcibly (3) resisted, obstructed, or

interfered with (4) a law enforcement officer, (5) while the officer was lawfully

engaged in the execution of the officer’s duties.” K.W. v. State, 984 N.E.2d 610,

Court of Appeals of Indiana | Memorandum Decision 18A-CR-1416 | December 26, 2018 Page 5 of 7 612 (Ind. 2013).

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Related

K.W. v. State of Indiana
984 N.E.2d 610 (Indiana Supreme Court, 2013)
Michael J. Lock v. State of Indiana
971 N.E.2d 71 (Indiana Supreme Court, 2012)
Graham v. State
903 N.E.2d 963 (Indiana Supreme Court, 2009)
Johnson v. State
833 N.E.2d 516 (Indiana Court of Appeals, 2005)
Lopez v. State
926 N.E.2d 1090 (Indiana Court of Appeals, 2010)
Spangler v. State
607 N.E.2d 720 (Indiana Supreme Court, 1993)
Demetrius Walker v. State of Indiana
998 N.E.2d 724 (Indiana Supreme Court, 2013)
Courtney Glenn v. State of Indiana
999 N.E.2d 859 (Indiana Court of Appeals, 2013)

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