Elmer J. Bailey, Appellant (defendant Below) v. State of Indiana, Appellee (plaintiff Below)

Summary

The Indiana Supreme Court held that any physical pain resulting from a rude, insolent, or angry touching satisfies the statutory definition of bodily injury, without a minimum severity or duration requirement. Because the victim testified that the defendant's repeated poking and shoving caused her pain, the evidence was sufficient to support his domestic-battery conviction. The court also held that his two-year sentence was appropriate in light of the offense and his criminal history.