Thursday, May 23, 2013

Trimble v. State case brief

Trimble v. State case brief
848 N.E.2d 278

CASE SYNOPSIS: Defendant filed a petition for rehearing of a judgment upholding a decision by the trial court (Indiana) that convicted him of cruelty to an animal and harboring a non-immunized dog; defendant claimed that the evidence was insufficient to prove that he abandoned or neglected a dog, and that the trial court required him to prove his innocence in violation of his due process rights.

FACTS: At the close of the State's case-in-chief, and in response to defendant's motion for a directed verdict, the trial judge expressed his "wavering" on whether defendant knowingly or intentionally tortured or mutilated the dog and commented that defendant would need to proffer evidence to rebut the State's claim of neglect. The trial judge acknowledged that the State had offered sufficient evidence to prove defendant's guilt, but reserved decision until after defendant presented his defense. The Court of Appeals reversed, finding that the State's evidence was gathered in violation of the federal and Indiana constitutions. The state supreme court found that the evidence of the dog's starved appearance, injured leg, and frost bitten extremities was sufficient to allow the trial judge to discount defendant's testimony and to infer that he failed to feed and care for the dog. The trial court's statement did not shift the burden of proof from the State to defendant. Rather, it simply expressed the conclusion that the evidence offered by the State in its case-in-chief was sufficient to deny a directed verdict and to require the defense to put on its case.

CONCLUSION: The petition for rehearing was granted, and the trial court's judgment was affirmed.

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