A Henry County driver just won an appeal after receiving a single-dollar fine. Layke Leonard had been ticketed for an unsafe start after a police officer heard his tires squeal as he pulled away from a traffic light before dawn, and in September the Indiana Court of Appeals wiped the conviction off the books entirely.
The case traces back to roughly 4:30 a.m. on October 6, 2025, when Officer Eric Jackson pulled Leonard over after watching his car peel out and hearing his tires screech as he accelerated from a green light, according to appellate court records cited by Justia Law. Jackson cited him for unsafe start, a Class C civil infraction under Indiana Code section 9-21-8-23, which bars drivers from starting a stopped or parked vehicle until the movement can be made with reasonable safety. At trial in Henry Circuit Court, Judge David L. McCord found Leonard guilty and ordered him to pay a $1 fine plus $139.50 in court costs, as reported by WISH-TV.
That nominal dollar amount didn't stop Leonard from pushing back. He argued the officer's testimony — that tires squeal when they lose traction and that this alone creates an unsafe condition — wasn't enough to prove he'd actually driven dangerously, per WISH-TV's reporting. The case turned on whether that testimony was enough to establish an unsafe start.
Appeals Court Says Squealing Tires Aren't Enough
On September 16, the Indiana Court of Appeals agreed with Leonard, reversing the bench-trial conviction out of Henry Circuit Court's Cause No. 33C03-2510-IF-3889. Appellate Judge Melissa May authored the unanimous four-page opinion, with Judges Rudolph Pyle III and Stephen Scheele concurring, the station's report indicates. The panel concluded the officer never testified that Leonard's vehicle moved erratically or dangerously — only that it made noise.
Leonard was represented on appeal by attorney Nathan Vining of Indianapolis-based Vining Legal LLC, while the Office of the Indiana Attorney General argued on behalf of the state, per the same account. The court's ruling leaned heavily on a 2000 precedent, Dora v. State, which held that tire spinning and squealing alone do not constitute an unsafe start without evidence the driver actually posed a threat to safety, as detailed by The Indiana Lawyer.
Drawing a Line Between Noise and Danger
The appellate judges distinguished Leonard's situation from Beasey v. State, a 2005 ruling upheld on appeal because the squealing tires in that case accompanied the vehicle fishtailing out of a parking lot. That comparison, laid out by The Indiana Lawyer, underscores the evidentiary line Indiana courts have drawn: sound alone doesn't cut it, but sound paired with visible loss of control does.
In Indiana civil infraction cases, the state carries the burden of proving a violation by a preponderance of the evidence under Indiana Code section 34-28-5-1(d), though appellate courts apply the same sufficiency-of-evidence standard used in criminal appeals, Justia Law notes. Here, the appeals court found no reasonable trier of fact could have concluded Leonard's driving was unsafe based solely on the officer's account of a loud start.
Indiana Code section 34-28-5-4 allows fines of up to $500 for a Class C civil infraction, while the trial court fined Leonard $1, according to FindLaw. With the conviction reversed, both the fine and the roughly $140 in court costs are off Leonard's ledger — and so, presumably, are the four demerit points that came with it.
