Lucas v. State
Indiana Supreme Court
413 N.E.2d 578 (1980)
- Written by Arlyn Katen, JD
Facts
A jury convicted Willard Wayne Lucas (defendant) of kidnapping and first-degree murder for the 1977 killing of Betty Dye. Before Captain Harold Trees arrested Lucas, Trees watched Lucas kneel by Dye’s bloody body and apologize for killing her. Trees saw that Lucas’s white shirt and blue pants were spotted with blood. After booking Lucas at the police station, police put Lucas’s shirt and pants in a plastic bag. Officer Johnson tied the bag shut, initialed it, and then left it unattended for 15 to 20 minutes. Johnson then placed the bag in an unlocked closet inside a room that was not accessible to the public. The bag was unattended for up to two hours until Johnson returned to retrieve it. Johnson noticed that the bag appeared to be in the same condition that he had left it in. Johnson delivered the bag to another officer, who initiated blood-type testing on the shirt and pants. At trial, Trees identified the shirt and pants as the same shirt and pants that Lucas was wearing when Trees arrested Lucas. The trial court admitted the shirt and pants into evidence, over Lucas’s objection. Lucas appealed his conviction and raised several issues. In relevant part, Lucas argued that the trial court had erred by admitting the shirt and pants despite police’s failure to maintain a proper chain of custody. Lucas did not allege that the evidence had been tampered with.
Rule of Law
Issue
Holding and Reasoning (Prentice, J.)
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