Lucas v. State
303 Ga. 134
Ga.2018Background
- On July 22, 2008, Dequontist Lucas and another man robbed Samuel Steward and Demarco Tyler; Steward was fatally shot and Tyler wounded. Lucas was identified at trial by eyewitnesses and by his then-girlfriend, Quatney Sapee.
- Sapee testified that she drove Lucas and others to the scene, saw Lucas shoot Steward, and related threats Lucas made to her after the shooting; her pretrial statements to an investigator varied somewhat from her trial testimony.
- A.L., a nearby resident, positively identified Lucas at trial as the shooter; his wife also saw the shooting but could not identify the shooter in court.
- Lucas was charged with multiple offenses, convicted by a Cobb County jury (including malice murder and armed robbery), and sentenced to life plus additional consecutive terms; he does not challenge sufficiency of the evidence.
- On appeal Lucas argued the trial court erred by limiting cross-examination of two prosecution witnesses: (1) A.L. regarding his immigration status, and (2) Sapee regarding potential sentences she might face if charged.
Issues
| Issue | Lucas's Argument | State's Argument | Held |
|---|---|---|---|
| Whether defense could cross-examine A.L. about undocumented immigration status to show bias | Immigration status could motive A.L. to curry favor with prosecutors or avoid deportation, so it was relevant to bias | Immigration status had only speculative relevance, little probative value, and risked unfair prejudice; no evidence of promises or threats from state | Court upheld limitation: trial court did not abuse discretion in barring questions about immigration status because relevance to bias was speculative and probative value was low |
| Whether defense could ask Sapee about potential sentences she would face if prosecuted (to show motive to cooperate) | Lucas wanted to probe potential penalties Sapee might avoid, showing motive to testify favorably | Sapee had not been charged or received any deal; questions about hypothetical sentences would be speculative and impermissible | Court affirmed limitation: defendant may question witness about bias generally, but may not force speculation about potential punishments absent a concrete deal |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (legal sufficiency standard)
- Davis v. Alaska, 415 U.S. 308 (cross-examination to expose bias is constitutionally protected)
- Nicely v. State, 291 Ga. 788 (trial court discretion to limit cross-examination)
- Hodo v. State, 272 Ga. 272 (right to inquire into witness partiality)
- Hampton v. State, 289 Ga. 621 (reasonable cross-exam on witness's belief of personal benefit)
- Olds v. State, 299 Ga. 65 (probative value depends on logical connection to fact)
- Sandoval v. State, 264 Ga. 199 (evidence that may unfairly prejudice jurors may be excluded)
- Vogleson v. State, 275 Ga. 637 (permitted inquiry into witness's belief about prison time avoided when witness has a deal)
- Smith v. State, 300 Ga. 538 (prohibiting speculation about potential penalties when no concrete plea deal exists)
- Kolokouris v. State, 271 Ga. 597 (Confrontation Clause guarantees reasonable opportunity for cross-examination)
- Cheley v. State, 299 Ga. 88 (trial court did not abuse discretion in limiting cross-examination about charges and potential sentences of informants)