The Indiana Court of Appeals upheld a man’s conviction for battery against his daughter on Wednesday but expressed concern over the lack of guidance courts are given when trying to determine when parental discipline goes too far.
The case of Sauntio Carter v. State of Indiana, 49A04-1511-CR-1823, began on Aug. 24, 2015, when Sauntio Carter’s 14-year-old daughter, M.C., lied about altering her eyebrows. As punishment, Carter took his daughter’s cellphone and discovered sexual content on her social media accounts.
The next day, M.C. took her phone and a pair of Carter’s shoes before leaving for school. When Carter discovered that M.C. had taken her phone and his shoes without permission, he went and found her at the bus stop and forced her to come home and change shoes. On the walk back, Carter broke M.C.’s cellphone.
According to Carter, when he arrived home he instructed his daughter to begin cleaning the apartment and determined that he would discipline her 14 times because she was 14 years old. Although Carter told her to bend over and touch the couch, he said his daughter jumped off the couch and raised her hand toward him. Carter’s father was on the phone and advised him to take a shower before disciplining her, so after his shower he spanked M.C. 14 times with his belt.
But in M.C.’s account, Carter told her to take off her sweater and shoes and then instructed her to bend over the couch. He then began hitting her with his belt on her back, legs and buttocks. M.C. also said her father shoved her against a wall and pressed his arm across her neck to the point that she was having trouble breathing.
M.C. said her father then instructed her to clean the apartment, showered, then returned and hit her again multiple times. M.C. also said she balled up her first, prompting Carter to smack her across the face.
When M.C. returned to school the next day, she told her guidance counselor that her arm hurt, and the counselor noticed a bruise on her shoulder. The counselor was able to glean a few details about the incident from M.C. and told the school nurse and Indiana Department of Child Services. A DCS assessment worker arrived at the school and took photos of the bruises on M.C.’s body, which were located on her buttocks, thigh, arm and shoulder.
Carter was subsequently charged and convicted of Class A misdemeanor battery resulting in bodily injury. He appealed, claiming there was insufficient evidence to support his battery conviction and asserted the parental discipline privilege as a defense.
In a Wednesday opinion affirming Carter’s convictions, the Indiana Court of Appeals wrote that it did not doubt that Carter reasonably believed M.C. needed to be punished, and even went so far as to say that the panel was “troubled by the lack of clear guidance for parents to be able to distinguish between reasonable discipline and battery.”
However, the appellate court also wrote that it is the duty of the trial court to weigh the evidence, not the appellate court, so the panel found that there was sufficient evidence to support his convictions.
Judge Terry Crone concurred with a separate opinion, writing that the Indiana Supreme Court had made the task of determining when parental discipline goes too far even harder by “importing the vague reasonableness standard of the Restatement of Torts into the criminal arena.”