Lucas v. State
810 S.E.2d 490
Ga.2018Background
- On July 22, 2008, Dequontist Lucas and an accomplice robbed Samuel Steward and Demarco Tyler; Steward was fatally shot and Tyler was wounded.
- Quatney Sapee (Lucas’s then-girlfriend) and eyewitness A.L. identified Lucas as the shooter; Sapee’s pre-trial statements and trial testimony varied.
- Sapee had driven Lucas and others that evening; she remained silent about the shooting for nearly three years and later told investigators about it.
- A.L. was unlawfully present in the United States at trial; Lucas sought to cross-examine him about immigration status as evidence of potential bias.
- Lucas also sought to question Sapee about potential sentences she might face if charged, to show motive/bias. The trial court limited both lines of cross-examination.
- Lucas was convicted of murder, armed robbery, and related offenses; he appealed arguing the limitations on cross-examination violated his confrontation/cross-examination rights. Court affirmed.
Issues
| Issue | Lucas's Argument | State's Argument | Held |
|---|---|---|---|
| Whether trial court erred by prohibiting cross-examination of A.L. about immigration status | Immigration status could show bias; A.L. might shade testimony to avoid deportation | Immigration status speculative, low probative value; no evidence prosecutors threatened/promise relief; prejudice to witness | Court upheld exclusion: discretionary limit not an abuse given speculative relevance and risk of unfair prejudice |
| Whether trial court erred by prohibiting questions to Sapee about potential sentences she might face if charged | Sapee might avoid prosecution or hope for leniency and thus had motive to testify favorably; Lucas entitled to probe this | Sapee had not been charged or promised a deal; questions about hypothetical sentences are speculative and inadmissible | Court upheld limitation: defendant may probe bias generally but not speculative sentencing hypotheticals |
| Whether limitations violated Confrontation Clause/right to thorough cross-examination | Excluding these topics deprived Lucas of exposing witness bias and motivations | Confrontation Clause allows reasonable limits; trial court retained wide latitude to restrict marginally relevant or prejudicial questioning | Court ruled constitutional rights preserved; limits were reasonable and not an abuse of discretion |
| Sufficiency of evidence to support convictions (independently reviewed) | N/A (Lucas conceded sufficiency) | State: evidence sufficient | Court independently found evidence sufficient to support convictions |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of the evidence)
- Davis v. Alaska, 415 U.S. 308 (cross-examination to expose bias is constitutionally protected)
- Nicely v. State, 291 Ga. 788 (trial court discretion in limiting cross-examination)
- Hodo v. State, 272 Ga. 272 (right to inquire into witness partiality; limits where speculative)
- Olds v. State, 299 Ga. 65 (probative value depends on logical connection and quality of evidence)
- Hampton v. State, 289 Ga. 621 (defendant entitled to reasonable cross-examination on belief of personal benefit)
- Kolokouris v. State, 271 Ga. 597 (Confrontation Clause guarantees opportunity, not unlimited effectiveness)
- Vogleson, 275 Ga. 637 (witness belief about avoided prison time must be allowed when witness testifies in exchange for reduced time)
- Smith v. State, 300 Ga. 538 (prohibiting speculation about potential penalties where no concrete plea deal exists)
- Lemons v. State, 270 Ga. App. 743 (no entitlement to question witnesses about immigration where no promises/offers shown)
- Cheley v. State, 299 Ga. 88 (limits on cross-examining informants about charges/sentences upheld)
- Sandoval v. State, 264 Ga. 199 (danger of unfair prejudice from impeachment by character-related evidence)