Patterson v. State

In August 2010, Melissa Patterson (defendant) was the victim of a domestic-battery incident committed by Gregory Darden. Patterson obtained a protective order against Darden, which prohibited Darden from having any contact with Patterson. However, after Patterson had obtained the protective order, Patterson and her daughter began living with Darden. After the local sheriff’s office discovered the living arrangement, Patterson and Darden were arrested. The state of Indiana (plaintiff) charged Darden for violating the order and charged Patterson with aiding Darden’s violation of the order. While the charges were pending, Darden and Patterson continued to have contact with each other. In November 2011, law-enforcement officers obtained an arrest warrant for Darden. While arresting Darden at his residence, the officers found Patterson there. Patterson was arrested and charged with a second count of aiding Darden’s violation of the no-contact order. In December 2011, Patterson filed a motion to dismiss the charges on the ground that the victim protected by a no-contact order could not be criminally charged with aiding the restrained party’s violation of the order. The trial court denied the motion. Patterson moved for an interlocutory appeal, which the trial court granted. The Indiana Court of Appeals accepted the appeal and considered whether the person protected by the no-contact protective order could be held criminally liable for aiding, inducing, or causing the restrained party to violate the order.