Ethane Potts v. State of Indiana

CourtIndiana Court of Appeals
DecidedJuly 11, 2025
Docket24A-CR-02072
StatusPublished

This text of Ethane Potts v. State of Indiana (Ethane Potts v. State of Indiana) 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
Ethane Potts v. State of Indiana, (Ind. Ct. App. 2025).

Opinion

FILED Jul 11 2025, 8:59 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana Ethane Potts, Appellant-Defendant

v.

State of Indiana, Appellee-Plaintiff

July 11, 2025 Court of Appeals Case No. 24A-CR-2072 Appeal from the St. Joseph Superior Court The Honorable David L. Francisco, Judge Trial Court Cause No. 71D02-2309-F3-52

Opinion by Judge Vaidik Judges Bailey and DeBoer concur.

Court of Appeals of Indiana | Opinion 24A-CR-2072 | July 11, 2025 Page 1 of 10 Vaidik, Judge.

Case Summary [1] Ethane Potts was convicted of one count of rape by sexual intercourse and one

count of rape by “other sexual conduct” after forcing his victim—the mother of

his children—to perform oral sex on him and then having sexual intercourse

with her against her will. He argues that these two convictions for two forms of

rape under the rape statute constitute double jeopardy. To establish double

jeopardy, he must show, in part, that one offense was “included” in the other,

either “inherently” or “as charged,” or that the charging information was

ambiguous as to whether one offense was included in the other. But as

explained below, sexual intercourse and “other sexual conduct” are mutually

exclusive acts, so one can never be included in the other, either inherently or as

charged. We therefore affirm both of Potts’s convictions. We also affirm his

sentence of 22 years, with 18 years to serve and 4 years suspended to probation.

Facts and Procedural History [2] The evidence most favorable to the convictions and sentence is as follows. Potts

and his victim, L.B., began dating in approximately 2017, during their freshman

year of high school. They had an “on again off again” relationship over the next

several years, Tr. Vol. II p. 237, and they have two young children.

[3] Potts and L.B. last had consensual sex in early July 2023, but by July 24 they

had broken up and begun seeing other people. That day, L.B. was at work

when she heard that Potts had impregnated another woman. She and Potts Court of Appeals of Indiana | Opinion 24A-CR-2072 | July 11, 2025 Page 2 of 10 began a long text-message exchange in which Potts denied the report but

accused L.B. of cheating on him, and L.B. repeatedly asked Potts to leave her

alone and told him that their relationship was over and “[t]here is no make up.”

Exs. 2-38. When L.B. acknowledged that she had “hooked up” with someone,

Potts threatened to do “some crazy s***” if she didn’t tell him who it was. Exs.

40-43. After L.B. named the man, Potts insisted that he would see her later

despite her unwillingness to see him. Exs. 43-46. Potts added, “[Y]ou’re gonna

get f***ed[.]” Ex. 46. When L.B. continued to refuse to see him, Potts said

again, “I’m gonna f*** you[.]” Exs. 47-48. L.B. finally agreed to meet Potts

outside during a short break at work because she was afraid that he would come

inside and make a scene that would cause her to lose her job. A co-worker

noticed that L.B. “seemed panicky, kind of frantic,” and nervous. Tr. Vol. II

pp. 151-52. L.B. wanted to meet in a public place, but Potts insisted that she get

in his car when he arrived, and she complied.

[4] Potts drove to a nearby parking garage. He wanted L.B. to give him oral sex,

which she refused to do multiple times. Id. at 111-12. Despite L.B. physically

resisting, Potts eventually forced her mouth onto his penis for a short time.

Potts then made L.B. remove her pants and had sexual intercourse with her in

the passenger seat, as L.B. asked him to get off her. When Potts was finished,

he returned to the driver’s seat while L.B. cried. L.B. asked Potts if he “realized

what he did,” and Potts acknowledged that he “forced himself” on her. Id. at

119. He said it would have been “really f***ed up” if he had done that to “a

Court of Appeals of Indiana | Opinion 24A-CR-2072 | July 11, 2025 Page 3 of 10 random person” but that this was “just [her].” Id. at 120. The visit to the

parking garage lasted 20 minutes.

[5] Potts drove L.B. back to work. When she went inside, she looked “[p]etrified”

and was shaking, and her clothes were “messed up.” Id. at 152-53. L.B. told her

co-worker that Potts had raped her. Later that afternoon, Potts texted L.B. that

he was going to pick up their son from the babysitter. L.B. responded, “Do you

not realize what you just did?” and “Like what in your right mind told you that

you could do that to me[?]” Exs. 57-58. When Potts claimed not to know what

she was talking about, L.B. told him that she had spent the last hour and a half

crying and “trying to decide whether to report it[.]” Ex. 58. Potts responded

with a series of messages urging L.B. not to report him, warning that if she did,

her children would lose their father forever. Exs. 58-64. That night, L.B. went

to a hospital, reported the assault, and submitted to a sexual-assault

examination.

[6] The State charged Potts with four counts of Level 3 felony rape under Indiana

Code section 35-42-4-1, which provides that rape can be committed by sexual

intercourse or by “other sexual conduct.” Of the four counts against Potts, two

were based on the act of sexual intercourse and two were based on the act of

“other sexual conduct” (Potts forcing L.B. to perform oral sex on him):

Count I: [Potts] did knowingly have sexual intercourse with [L.B.] when [L.B.] attempted to physically, verbally, or by other visible conduct refuse [Potts’s] act.

Court of Appeals of Indiana | Opinion 24A-CR-2072 | July 11, 2025 Page 4 of 10 Count II: [Potts] did knowingly cause [L.B.] to perform or submit to other sexual conduct [when L.B.] attempted to physically, verbally, or by other visible conduct refuse [Potts’s] act.

Count III: [Potts] did knowingly have sexual intercourse with [L.B.] when such person was compelled by force or the imminent threat of force.

Count IV: [Potts] did knowingly cause [L.B.] to perform o[r] submit to other sexual conduct when such person was compelled by force or the imminent threat of force.

Appellant’s App. Vol. II pp. 13-14.

[7] A jury trial was held in July 2024. Potts admitted to engaging in sexual activity

with L.B. but claimed it was all consensual. The jury disagreed and found Potts

guilty as charged. When the court ordered Potts remanded into custody

pending sentencing, he tried to run out of the courtroom and had to be subdued

by court security.

[8] At the sentencing hearing, the court and the parties agreed that four rape

convictions would constitute double jeopardy but that two convictions—one for

sexual intercourse and one for “other sexual conduct” (oral sex)—would not.

The court entered convictions on Count I and Count IV.

[9] In sentencing Potts on those two counts, the trial court found his criminal

history to be an aggravating circumstance. Potts has prior misdemeanor

convictions for criminal mischief, possession of marijuana, and possession of

paraphernalia. L.B. was the victim of the criminal mischief, and Potts was on

Court of Appeals of Indiana | Opinion 24A-CR-2072 | July 11, 2025 Page 5 of 10 probation for the marijuana and paraphernalia convictions when he committed

these offenses. The court also found the nature and circumstances of the

offenses to be aggravating, including Potts “gaslighting [L.B.] and attempting to

emotionally manipulate her, through the children, to not report his criminal

conduct.” Id.

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Related

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54 N.E.3d 1041 (Indiana Court of Appeals, 2016)

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Ethane Potts v. State of Indiana, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ethane-potts-v-state-of-indiana-indctapp-2025.