## Facts

- Sauntio A. Carter disciplined his 14-year-old daughter, M.C., after noticing she had altered her eyebrows and then lied about it.
- As punishment, Carter confiscated M.C.’s cell phone and reviewed her social-media accounts.
- Carter saw that M.C. had posted photos of herself wearing only underwear, communicated with boys in a sexual manner, and posted both her own and her grandmother’s addresses online.
- The next day, M.C. took the phone back before leaving for school and also took a pair of Carter’s shoes.
- Carter walked to the bus stop, found M.C., and brought her back home; during the walk he broke M.C.’s cell phone.
- Carter decided to impose corporal punishment. Carter testified that he had M.C. clean the apartment, called his father to discuss M.C.’s behavior, took a shower to calm down, and then spanked M.C. fourteen times with his belt.
- M.C. testified that Carter hit her with the belt repeatedly throughout the day and at one point pressed her against a wall, making it hard for her to breathe.
- The next day at school, M.C. reported what happened to a guidance counselor, who observed numerous bruises on M.C.’s body.
- The school nurse contacted the Indiana Department of Child Services, and a department representative photographed M.C.’s bruises.
- The State charged Carter with strangulation and battery. After a bench trial, Carter was acquitted of strangulation but found guilty of Class A misdemeanor battery resulting in bodily injury, based on a finding that his force was unreasonable and not justified as parental discipline.

## Issues

1. Whether sufficient evidence supported Carter’s conviction for battery resulting in bodily injury where he claimed the parental-discipline privilege.
2. Whether the evidence permitted the trial court to find beyond a reasonable doubt that Carter’s use of force (or his belief in its necessity) was unreasonable, defeating the privilege.

## Decision

- The Court of Appeals of Indiana affirmed Carter’s battery conviction.
- The court applied the standard sufficiency review: it would not reweigh evidence or judge witness credibility and would consider only the evidence and reasonable inferences supporting the judgment.
- Indiana recognizes a parental privilege to use corporal punishment, but only reasonable force; whether force is reasonable is a fact question for the factfinder.
- Evidence showed Carter struck M.C. with a belt at least fourteen times and that school personnel and DCS documented numerous bruises the next day.
- Based on the belt strikes and the extent of bruising and pain, the trial court could find the punishment exceeded reasonable parental discipline.
- Because the factfinder could conclude the force was unreasonable, the State negated the parental-discipline defense and proved battery resulting in bodily injury beyond a reasonable doubt.

## Legal Principles

- A parent has a common-law privilege to use reasonable corporal punishment to discipline a child.
- When the parental-discipline justification is in issue, the State must disprove it beyond a reasonable doubt by showing the force used was unreasonable (or that the parent’s belief in the need for that force was unreasonable).
- In assessing whether corporal punishment is reasonable, the factfinder may consider factors such as the child’s age, the child’s misconduct, the instrument used, the amount of force, the extent of injury, and whether the punishment was administered calmly or in anger.
- Battery resulting in bodily injury requires proof of a knowing or intentional rude, angry, or insolent touching that causes bodily injury.
- On appellate review for sufficiency of the evidence, the court does not reweigh evidence or assess witness credibility and will affirm if a reasonable factfinder could find the elements proved beyond a reasonable doubt.

## Conclusion

The conviction was affirmed because the evidence that Carter struck his 14-year-old daughter with a belt at least fourteen times and left numerous bruises documented at school and by DCS supported the trial court’s finding that the force was unreasonable, placing it outside the parental-discipline privilege and satisfying the elements of battery resulting in bodily injury.


Carter v. State, 67 N.E.3d 1041 (2016)