## Facts

- Willard Wayne Lucas was indicted for first-degree murder and kidnapping arising from the death of Betty Dye.
- A sheriff’s captain responded to a vehicle crash near Dye’s home, found Dye’s identification in a handbag, and proceeded toward her residence.
- The captain observed a white Chevrolet leaving a nearby barn area associated with an earlier alleged attack on Dye for which Lucas had been charged and was on bond.
- After stopping the Chevrolet for a traffic violation, the captain observed damage to the vehicle and that Lucas’s clothing appeared to have blood spots.
- The captain returned to the barn area and located Dye’s body; Lucas was arrested near the scene.
- At booking, officers removed Lucas’s shirt and pants, placed them in a plastic bag, tied and initialed the bag, and left it unattended for brief periods, including storage in an unlocked closet in a non-public room, before submitting the items for testing.
- Police also obtained a blood sample from Lucas and transported it to a state laboratory for blood-typing.
- At trial, Lucas objected to admission of the clothing and blood evidence based on claimed chain-of-custody deficiencies; he also challenged admission of incriminating statements and physical evidence derived from them, certain background testimony about a witness’s acquaintance with him, and refusal of a proposed jury instruction on the right to remain silent.
- A jury convicted Lucas on both counts, and he received a life sentence.

## Issues

1. Whether Lucas’s incriminating statements during police interrogation were admissible.
2. Whether physical evidence obtained as a result of those statements was admissible.
3. Whether the State established an adequate chain of custody for Lucas’s clothing despite unattended periods and storage in an unlocked area.
4. Whether the State established an adequate chain of custody for Lucas’s blood sample submitted for laboratory testing.
5. Whether testimony describing a witness’s prior acquaintance with Lucas was improperly prejudicial.
6. Whether the trial court erred by refusing Lucas’s tendered instruction concerning his right to remain silent.

## Decision

- The Indiana Supreme Court affirmed the convictions for first-degree murder and kidnapping.
- The court upheld admission of Lucas’s statements and evidence derived from them.
- The court held the clothing and blood sample were properly admitted because the State showed a reasonable probability the items were not altered or tampered with.
- The court held testimony about a witness’s prior acquaintance with Lucas was permissible background evidence.
- The court held refusal of the tendered right-to-silence instruction was not reversible error because the jury instructions, read as a whole, adequately covered the substance of the law.

## Legal Principles

- To admit physical evidence, the State must show a reasonable probability the evidence has not been altered or tampered with; it need not eliminate every speculative possibility of contamination or substitution.
- Minor gaps or weaknesses in the chain of custody generally affect the weight of the evidence for the jury, not its admissibility, absent a concrete showing of tampering.
- Evidence sealed or identified by officers and kept in a non-public area may satisfy the chain-of-custody threshold even if it is briefly unattended or stored in an unlocked location, where its condition appears unchanged and no tampering is shown.
- A trial court may refuse a tendered instruction when the substance of the proposed instruction is adequately covered by other instructions as a whole.

## Conclusion

The court affirmed Lucas’s convictions, applying a reasonable-probability standard to chain of custody and treating unattended storage and other minor handling gaps as matters for the jury’s evaluation of evidentiary weight rather than grounds for exclusion, while also rejecting challenges to the interrogation evidence, a background witness statement, and the refusal of an additional silence instruction.


Lucas v. State, 413 N.E.2d 578 (Ind. 1980)