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Smith v. State of Indiana

8 N.E.3d 668 (2014)

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Smith v. State of Indiana

Indiana Supreme Court

8 N.E.3d 668 (2014)

Facts

Christopher Smith (plaintiff) was the principal at Muncie Central High School (Muncie). G.G., a 16-year-old student, reported to school administrators that she had been raped in the bathroom at lunchtime by S.M., another 16-year-old student. The school immediately reported the rape to G.G.’s guardians, who took her to the hospital; however, Smith failed to inform law enforcement or the Indiana Department of Children’s Services (DCS). In the four hours following G.G.’s report, Smith conducted his own investigation, interrogated S.M., and then interviewed candidates for an unrelated administrative position. S.M. was allowed to return to class after speaking with Smith. Police learned about G.G.’s rape following her admission to the hospital for a sexual-assault examination. S.M. ultimately pleaded guilty to raping G.G. The State of Indiana (defendant) then charged Smith, a mandated reporter, with failing to immediately report G.G.’s rape allegations. Smith challenged, arguing that (1) Indiana’s mandatory reporting statute was vague because it failed to define what constituted an immediate report; (2) a report within 24 hours should count as immediate; and (3) he was unaware that student-on-student rape constituted reportable child abuse. The trial court convicted Smith after a bench trial. Smith appealed, and the appellate court reversed, holding that Smith could not be held liable because he was unaware that student-on-student rape constituted reportable child abuse. Indiana appealed.

Rule of Law

Issue

Holding and Reasoning (David, J.)

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