State of Washington v. Timothy Lucious

CourtCourt of Appeals of Washington
DecidedMarch 12, 2024
Docket39338-1
StatusUnpublished

This text of State of Washington v. Timothy Lucious (State of Washington v. Timothy Lucious) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Washington v. Timothy Lucious, (Wash. Ct. App. 2024).

Opinion

FILED MARCH 12, 2024 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

STATE OF WASHINGTON, ) No. 39338-1-III ) Respondent, ) ) v. ) UNPUBLISHED OPINION ) TIMOTHY LUCIOUS, ) ) Appellant. )

PENNELL, J. — In 2010, a jury convicted Timothy Lucious of one count of

drive-by shooting and six counts of second degree assault with a deadly weapon. In 2022,

Mr. Lucious filed a motion for postconviction DNA testing of ammunition evidence.

The trial court denied the motion. We affirm.

BACKGROUND

The incident leading to Mr. Lucious’s criminal charges took place in July 2009

when a group of friends went out in Spokane for a birthday celebration. While out at a

bar—and then later at a house party—the friends ran into a woman previously unknown

to them who was confrontational and aggressive. The woman appeared to be an

acquaintance of Mr. Lucious. Eventually, one of the friends arranged to fight the woman

at a local park. No. 39338-1-III State v. Lucious

When the group encountered the woman near the park, she was with several other

people, including Mr. Lucious. The fight began with a physical altercation but things

escalated when the woman wielded a razor blade and later a knife. At some point,

Mr. Lucious pulled out a handgun and waved it around. The friends got back in their

car to leave and Mr. Lucious tapped on the car window with his pistol. Mr. Lucious

asked the car’s occupants if they remembered him. Mr. Lucious also said, “‘Bitch,

I’ll shoot you’” to one of the friends. 2 Rep. of Proc. (Sept. 13, 2010) at 246, State v.

Lucious, No. 29545-1-III.

The group started to flee, but soon discovered they had left two of their members

behind. As they turned around to retrieve their friends, gunshots rang out. At least one

of the group members was hit by a bullet and the group drove off to a hospital. One of

the friends was critically injured and required eight days of hospitalization.

Police responded to the hospital and conducted interviews. Several of the group

members were shown a photo array and identified Mr. Lucious as the shooter. Law

enforcement investigated the scene of the shooting and recovered several 9-millimeter

shell casings. They did not find a firearm.

Mr. Lucious was charged with six counts of attempted first degree murder and

one count of drive-by shooting.

2 No. 39338-1-III State v. Lucious

At trial, the group members testified against Mr. Lucious. All identified

Mr. Lucious as their assailant with varying degrees of specificity. Some said they

observed him shoot the gun. Others merely testified that they saw Mr. Lucious wielding

the gun. Only one of the group members said they knew Mr. Lucious before the night of

the shooting. The defense impeached group members with evidence of intoxication and

prior false statements.

The jury convicted Mr. Lucious of one count of drive-by shooting and six counts

of the lesser-included offense of second degree assault with a deadly weapon. He

received a sentence of life in prison as a persistent offender. The convictions were

affirmed on appeal. State v. Lucious, No. 29545-1-III, slip op. at 1 (Wash. Ct. App.

May 23, 2013) (unpublished), https://www.courts.wa.gov/opinions/pdf/295451.pdf.

In July 2022, Mr. Lucious filed a motion under RCW 10.73.170 for postconviction

DNA testing of the shell casings. In support of the motion, he submitted a declaration

from Carol Vo, a forensic scientist at the Washington State Patrol Crime Laboratory.

Ms. Vo declared that she had reviewed the incident report from Mr. Lucious’s case and

determined no prior DNA testing had been performed. According to Ms. Vo, the shell

casings recovered from the crime scene could have yielded DNA evidence pertaining to

the individual who had loaded the ammunition into the gun.

3 No. 39338-1-III State v. Lucious

The State opposed Mr. Lucious’s motion. According to the State, even if testing

produced a result favorable to Mr. Lucious, it would merely mean that someone else had

handled the ammunition at some point in time. The State argued such a result would not

reasonably undermine the jury’s verdict.

The trial court agreed with the State and denied Mr. Lucious’s motion. In a letter

ruling, the court explained:

. . . [T]he Court is called upon to presume that another individual’s DNA would be found on the bullet casings and Mr. Lucious’s DNA would not. Mr. Lucious argues that whoever loaded the gun may be the individual responsible for firing the gun the night of the street brawl . . . . However, this theory is weakened by the fact that a gun can be loaded by one individual and fired by another. More compelling, even . . . assuming favorable DNA testing for Mr. Lucious, the favorable DNA testing would not demonstrate his innocence on a more probable than not basis in light of the evidence produced at trial.

At trial, evidence was admitted that Mr. Lucious was seen holding a firearm by six different witnesses, with five of the witnesses identifying him as the shooter. Even though eye-witness testimony may not be too reliable, the testimony is bolstered in this case due to the number of witnesses who saw Mr. Lucious with a gun. More importantly, it would be improper for the Court to assume the role of the jury and reweigh the credibility of the eye- witness testimony. Credibility determinations of each witness are left to the trier of fact as they are able to observe each witness while subject to direct examination and cross-examination.

. . . [T]he presumptively favorable DNA results would not demonstrate Mr. Lucious’s innocence on a more probable than not basis.

4 No. 39338-1-III State v. Lucious

Clerk’s Papers at 332. The trial court’s written order incorporated the letter ruling.

Mr. Lucious timely appeals.

ANALYSIS

Under RCW 10.73.170, an individual incarcerated for a felony offense may file

a postconviction motion requesting DNA testing of evidence. The statute imposes

procedural 1 and substantive 2 requirements. The procedural components are fairly

“lenient,” but the substantive requirement is “onerous.” State v. Riofta, 166 Wn.2d

358, 367, 209 P.3d 467 (2009). We review a trial court’s decision on a motion for

postconviction DNA testing for abuse of discretion. State v. Thompson, 173 Wn.2d

865, 870, 271 P.3d 204 (2012).

The only contested issue in this case is the substantive component of the statute.

This provision requires the applicant to show a “likelihood that the DNA evidence would

demonstrate innocence on a more probable than not basis.” RCW 10.73.170(3). Well-

established rules govern whether an applicant has satisfied the substantive component.

In considering a request for postconviction DNA testing, a court must afford the movant

the presumption that further testing will indicate the absence of the defendant’s DNA and

1 See RCW 10.73.170(2).

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Related

State v. Thompson
271 P.3d 204 (Washington Supreme Court, 2012)
State Of Washington v. Kevin Jory Braa
410 P.3d 1176 (Court of Appeals of Washington, 2018)
State v. Riofta
209 P.3d 467 (Washington Supreme Court, 2009)

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