Lawrence v. State
2012 Ind. App. LEXIS 10
| Ind. Ct. App. | 2012Background
- Charles Lawrence, Sr. was convicted of murder in Indiana for shooting Quinton Lewis in the apartment of Lewis's girlfriend, Tekeila.
- Lewis had previously battered Tekeila; Lawrence’s sister; there was motive to protect his sister from Lewis.
- Evidence showed a shell casing and a bullet trajectory indicating the first shot came from inside or just inside the apartment door.
- A handgun associated to the shell casings was found nearby, and forensic tests linked it to the casings.
- The State relied on circumstantial evidence and impeached witness testimony to place Lawrence at the scene.
- The trial court accepted certain statements by Tekeila as substantive evidence, aiding the jury’s finding of presence and opportunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there sufficient evidence to convict of murder? | Lawrence challenged sufficiency, focusing on impeachment-based presence. | Lawrence contends no substantive evidence he was at the scene. | Yes; substantial evidence showed presence and opportunity. |
| Did the State prove Lawrence at the scene through substantive evidence beyond impeachment? | Impeachment evidence dominated the record, not substantive proof. | Impeached statements could be substantive evidence under Rule 803(2) as excited utterances. | Yes; statements were admissible as substantive evidence and supported presence. |
| Were the impeaching statements properly admitted or waived for lack of limiting instructions? | Statements used for impeachment only should limit substantive use. | Defense did not object to their substantive use, waiving the issue. | Waived to the extent challenged; substantive use permissible as admitted. |
| Does the evidence support the habitual offender finding? | Not at issue in this appeal. | Challenge to habitual offender proof not raised on appeal. | Not challenged on appeal; sustained by separate ruling. |
Key Cases Cited
- Joslyn v. State, 942 N.E.2d 809 (Ind.2011) (reaffirms standard for reviewing sufficiency of evidence)
- Gray v. State, 957 N.E.2d 171 (Ind.2011) (gives standard for appellate review of sufficiency; limits reweighing evidence)
- Long v. State, 935 N.E.2d 194 (Ind.Ct.App.2010) (sufficiency may rely on circumstantial evidence)
- Gaby v. State, 949 N.E.2d 870 (Ind.Ct.App.2011) (impeachment evidence admissibility; substantive use limitations)
- Impson v. State, 721 N.E.2d 1275 (Ind.Ct.App.2000) (excited utterances admissible as substantive and impeachment evidence)
- Humphrey v. State, 680 N.E.2d 836 (Ind.1997) (upholds sufficiency where testimony places defendant at scene with corroboration)